CSRD for Indian companies: who reports, when, and what EU customers can ask for

The EU's Corporate Sustainability Reporting Directive (CSRD) was cut back sharply in 2025-26. Fewer companies report, later, against shorter standards. For an Indian group it still matters in three ways: through a large EU subsidiary, through a report for the whole group if its EU sales are large enough, and through EU customers asking for data. This guide sets out each, with the dates that apply as of October 2026.

What changed in 2025 and 2026?

Two EU laws rewrote the timetable and the scope:

• The "stop-the-clock" directive of April 2025 postponed the second and third waves of reporting by two years, so that the rules could be simplified first⁹.
• The Omnibus directive, Directive (EU) 2026/470, agreed by the Council and Parliament on 9 December 2025² and published in February 2026¹, then narrowed the CSRD for good.

Under the Omnibus:

The second wave — large EU companies that were not already reporting — now reports on financial year 2027, in 2028³. Companies that started reporting on FY 2024 continue, though member states may exempt those below the new thresholds for FY 2025 and FY 2026³.

Is your EU subsidiary in scope?

Look at each EU subsidiary, or EU sub-group, on its own. It reports under the CSRD if it has both more than 1,000 employees on average and more than €450 million net turnover¹. A subsidiary that meets both reports on FY 2027, in 2028, under the revised European Sustainability Reporting Standards (ESRS)⁷.

It can be exempted if the Indian parent publishes a consolidated sustainability report covering it, prepared under the ESRS or under a standard the European Commission recognises as equivalent⁷. As of October 2026 the Commission has not recognised any non-EU standard as equivalent — not ISSB-based standards, not US rules, and not BRSR⁸. In practice, the exemption means the parent reporting under the ESRS.

Does your group report under article 40a?

The CSRD also has a separate route for groups headquartered outside the EU. An Indian group is caught when¹⁴:

1. its net turnover in the EU exceeded €450 million in each of the last two consecutive financial years; and
2. it has an EU subsidiary with net turnover above €200 million — or, if it has none, an EU branch above €200 million.

There is no employee test. The first group reports cover financial year 2028 and are published in 2029, by the EU subsidiary or branch⁴.

These group reports are about the group's impacts on people and the environment, under a separate, shorter standard. EFRAG published an exposure draft of it — "ESRS-40a" — for consultation from 23 July to 31 October 2026⁴, with its advice to the Commission planned for January 2027¹⁰; the standard had not been adopted when this guide was checked. The report also needs an assurance opinion³.

What can EU customers ask you for?

This is where most Indian suppliers will meet the CSRD. Companies that report need data from their value chain — emissions, energy, workforce figures, policies — and they ask their suppliers.

The Omnibus introduced a value-chain cap. A "protected undertaking" — a company in the value chain with 1,000 employees or fewer — cannot be required to provide more than the information in the EU's voluntary standard for smaller companies, and may decline requests beyond it¹⁶. The list of datapoints in the cap was set in September 2026 and applies from FY 2027⁶.

Two limits to keep in mind:

• The cap limits requests made for CSRD reporting. Requests under other EU laws — due diligence, forced labour — are not capped by it⁶.
• Declining is a right, not a requirement. A supplier that can answer well — with a credible GHG inventory and evidence — is easier to buy from.

Our guide to collecting ESG data from sites and suppliers covers what buyers ask for, from the other side.

What about the revised ESRS?

The ESRS were cut and rewritten as well. EFRAG delivered its advice on 3 December 2025, and the Commission adopted the revised standards on 3 July 2026, reducing the mandatory datapoints by more than 60%⁵. They were published in the Official Journal in September 2026 as Delegated Regulation (EU) 2026/1563 and are mandatory for financial years beginning on or after 1 January 2027, with companies free to use them for 2026⁶.

For a reporting EU subsidiary, the revised ESRS still require a double materiality assessment: a topic is material if the company has significant impacts on it, or if it significantly affects the company's finances. Our comparison of GRI, ISSB, ESRS and BRSR explains how that differs from BRSR.

Does BRSR count?

Not directly. BRSR is a disclosure format under SEBI's rules for listed companies in India; the CSRD recognises the ESRS and, in future, standards the Commission declares equivalent — and none has been declared equivalent so far⁸. The work overlaps heavily, though: the GHG inventory, energy, water, waste, workforce and governance data behind a BRSR are much of what an ESRS report or a customer request needs. Keeping one approved figure for each and mapping it to each framework avoids collecting it twice.

A short note on the CSDDD

The Omnibus also narrowed the Corporate Sustainability Due Diligence Directive: it now covers companies with more than 5,000 employees and more than €1.5 billion turnover — for non-EU companies, more than €1.5 billion turnover in the EU — and applies from 26 July 2029¹². Few Indian groups will be in scope directly; more will be asked by EU customers about their own due diligence.

What to do now

1. Map your EU footprint by year: EU net turnover, and each EU subsidiary's and branch's turnover and employees. The two-year test means FY 2026 and FY 2027 figures already matter.
2. Decide who reports what: a large EU subsidiary on FY 2027; the group on FY 2028 if article 40a applies.
3. Build the GHG inventory and the core figures once, on the GHG Protocol, with evidence — they serve BRSR, customer requests and any ESRS report.
4. Prepare a standard customer answer based on the voluntary standard's datapoints, so requests from EU buyers take hours, not weeks.

How ESGTrack helps

ESGTrack keeps one approved figure and shows, framework by framework, where it is used — BRSR, GRI, ISSB, the ESRS and CDP. For an EU subsidiary it holds the double materiality assessment and the register of impacts, risks and opportunities, and the ESRS disclosures on the standards adopted in 2023 — which companies may still use for FY 2026 — with the revised ESRS shown as a regulatory update on the screens they affect. Supplier requests collect value chain data with its evidence. See frameworks and supplier and value-chain data.