CSRD

The CSRD put sustainability reports in the EU on a new footing, and shortly afterwards was cut back considerably again by the EU Omnibus. This entry gives an overview of the directive, its current scope and its relevance to IT hardware. As of 10/2026.

What is the CSRD?

The CSRD entered into force at the beginning of 2023 and replaced the previous directive on non-financial reporting (NFRD). It mainly amends the EU Accounting Directive. The most important innovations compared with the NFRD:

• Uniform standards: Reporting follows the European Sustainability Reporting Standards (ESRS).
• Double materiality: Companies report on their impacts on the environment and society and on financial risks and opportunities for themselves.
• Audit requirement: The sustainability report is audited externally, initially with limited assurance.
• Management report and digital format: The disclosures appear in the management report and are tagged in a machine-readable way.

Who is affected? (as of 10/2026)

Step	What applies
Original CSRD	Gradual extension to large companies and capital-market-oriented SMEs; first companies report for the 2024 financial year
"Stop-the-Clock" (Directive (EU) 2025/794)	Postponement of the later application waves by two years
Omnibus Directive (EU) 2026/470	In force since March 18, 2026; as a rule, only companies with more than 1,000 employees and more than EUR 450 million in turnover remain subject to reporting
Revised ESRS	Delegated Regulation of the EU Commission of July 3, 2026 with significantly fewer data points
Germany	Implementation takes place through a CSRD Implementation Act amending the HGB; the version of the law as promulgated at the time is decisive

The Omnibus greatly shrinks the circle of companies subject to reporting. Many mid-sized companies are no longer directly covered. The topic remains relevant indirectly: customers subject to reporting request data from their suppliers and service providers. Check the exact date of first application for your company with your auditor. This entry does not replace legal or tax advice.

Meaning for IT hardware

IT hardware touches several topical standards. Manufacturing, transport and disposal of the devices cause emissions that can feed into ESRS E1 as Scope 3 emissions (see Scope 1, 2 and 3). Procurement and decommissioning are resource inflows and outflows under ESRS E5. And decommissioned devices hold data whose protection is part of governance.

What counts for the report are figures with evidence: how many devices were reused, recycled or disposed of, with disposal proofs and erasure certificates. How the emissions side looks for IT hardware is explained in the guide Scope 3 emissions of IT hardware and CSRD.

CSRD and Second IT

Second IT provides recycling and disposal proofs for CSR and ESG reporting, plus a digitally signed erasure certificate for each device, audit reports in the customer portal and an annual, individual environmental balance. Devices are refurbished and remarketed according to the principle of reuse before recycling. What is no longer usable is disposed of by Second IT as a certified waste management company under § 56 KrWG. More on disposal with documentation.

Frequently asked questions about the CSRD

What is the difference between the CSRD and the ESRS?

The CSRD is the EU directive that determines who has to report and how the report is audited. The ESRS are the standards that determine what is in the report.

Does the CSRD still apply to my company after the Omnibus?

Under the Omnibus Directive, companies with more than 1,000 employees and more than EUR 450 million in turnover are generally subject to reporting (as of 10/2026). Special rules apply to groups, non-EU companies and transitional cases. Have the classification reviewed by an expert.

What role does decommissioned IT play in the CSRD report?

It can appear under the topics of resource use and circular economy (ESRS E5) and Scope 3 emissions (ESRS E1) if these topics are material. Reliable quantities and proof of the recovery routes are important.

What does double materiality mean in the CSRD?

Companies report on their impacts on the environment and society and at the same time on financial risks and opportunities for themselves. Both perspectives determine which topics must appear in the sustainability report.

Do I have to supply sustainability data to CSRD customers as a supplier?

That depends on whether your company is itself covered. Even without an obligation of your own, customers subject to reporting often request data from suppliers and service providers, for example on reuse, recycling and disposal with evidence.