Policy paper on the synergies between the Eco-Management and Audit Scheme (EMAS) and the Corporate Sustainability Reporting (CSRD) published

The Corporate Sustainability Reporting Directive (CSRD) adopted by the EU Parliament in November 2022 raises non-financial reporting elements such as environmental, social and governance to the same level as financial reporting. The reporting obligation for companies is being implemented gradually in the EU between 2024 and 2026, depending on the size of the company. From January 1, 2024 the first large public-interest companies have to comply with the CSRD (for reports published in 2025) if meeting two of the following three criteria: (1) Balance sheet total of at least 25 million euros, (2) net sales of at least 50 million euros, (3) number of employees more than 250. The exact details of the reporting are set out in the European Sustainability Reporting Standards (ESRS) formally adopted by the European Commission on the 31st July 2023. In the EU, around 50,000 companies will be subject to the CSRD of which 898 are EMAS certified.¹

In February 2024, the German EMAS Advisory Board (Umweltgutachterausschuss, UGA) published a Policy Paper on the Synergies between CSRD and EMAS. The paper resulted from the joint effort of a working group with various stakeholders, in which the European Commission was involved. It was also being consulted as part of an EMAS Committee meeting in November 2023.

The paper stresses that EMAS serves as a very good basis for complying with the ESRS: The intersection of EMAS and ESRS lies in the environmental pillar. This is also emphasized in the ESRS itself (Provision 121 of Annex 1) that allow to include references to the EMAS environmental statement. The discussion paper explores how the EMAS Environmental Statement can be integrated into the mandatory ESRS reporting. The discussion paper presents two options how this can be realised: Either a company can partly or fully integrate the information required by the ESRS in the (corporate) environmental statement and include respective references in the management report (Option 1). Besides this, EMAS provides the option to integrate the environmental statement in a sustainability report, provided that information validated by the environmental verifier is clearly identified as such and distinguished from other non-validated information (Option 2). It sheds light on the conditions that must be met to dovetail the ESRS report and the EMAS environmental statement:

• the information to comply with ESRS disclosure requirements is clearly identified in the environmental statement,
• the environmental statement refers to the same reporting period as the management report and is available latest by the time of publication of the management report,
• the information incorporated by reference is produced using the same basis for preparation of ESRS information, including scope of consolidation, i.e. the entities and sites addressed in the environmental statement must match those for which the management report is produced, and treatment of value chain information (see also ESRS 2 BP-1 and 2),
• the information in the environmental statement is subject to the same level of assurance as the sustainability information in the management report²,
• the environmental statement or the referenced parts of it are available in the same technical digitialzed format as the sustainability information which is requested for the management report (see Art. 29d CSRD).

EMAS Organisations can use their already established environmental management system as a foundation to meet some of the requirements of the ESRS. For example, the ESRS and EMAS have

similarities in their objectives, such as the enhancement of their sustainability performance and promotion of responsible business conduct. Moreover, management system elements, such as the PCDA cycle, serve as a good basis for reporting on policies, targets, actions and governance structures within the ESRS.

Some of the provisions in the ESRS go beyond the EMAS requirements: For instance, ESRS requires more details regarding the materiality assessment and performance indicators. In the discussion paper, a table (“The differences between both standards”) compares the requirements of EMAS with those of the ESRS.

The paper provides an initial overview on how it is possible to use EMAS as a tool to comply with the CSRD requirements. The EMAS working group works still with EFRAG to see how it is possible to facilitate further the use of EMAS data for the mandatory reporting and ensure there is alignment between the two requirements.

Link to Policy Paper: https://www.emas.de/fileadmin/user_upload/4-pub/Diskussionspapier_02_CS…

For listed SMEs (LSME), EFRAG has currently released the exposure draft for proportionate reporting requirements, that will be effective on 1 January 2026 with an additional two-year opt out. Together with an exposure draft for a voluntary sustainability reporting standard for non-listed SMEs (VSME) the two standards are open for public consultation until May 21. 

¹ Please note: This information is based on data from 19 out of 30 countries in which EMAS is applied. This means that more EMAS companies may be affected.

² Generally, the validation of information by an environmental verifier can be considered as equivalent to reasonable assurance requirements under the CSRD. See: Office of the German EMAS Advisory Board: Study on the Expertise Profile of Environmental Verifiers for the National Implementation of the CSRD Reporting Requirement (in German only). Source last accessed: 16.01.2024