CSRD and Your
African Operations

In 2026 the EU cut the Corporate Sustainability Reporting Directive (CSRD) back hard: fewer companies, fewer datapoints, later deadlines. For African businesses inside European groups or supply chains, the requests will be smaller and later than expected, but they are still coming.

This guide sets out what changed, who now reports and when, and what an African subsidiary or supplier will realistically be asked for. It reflects the rules as they stood in October 2026.

01: What changed in 2026

Two directives and a new set of standards

Three pieces of EU law reshaped the CSRD between 2025 and 2026.

• The "stop-the-clock" directive (Directive (EU) 2025/794, adopted April 2025) pushed back reporting by two years for large companies that had not yet started, and for listed SMEs.¹
• The Omnibus directive (Directive (EU) 2026/470, in force since 18 March 2026) narrowed who reports. Member States have until 19 March 2027 to write it into national law.²
• The revised European Sustainability Reporting Standards (ESRS), adopted by the Commission on 3 July 2026 and published on 21 September 2026, enter into force on 10 November 2026. They are mandatory for financial years starting on or after 1 January 2027.³

The Commission says the revised standards cut mandatory datapoints by more than 60%.⁴ Double materiality stays. Companies can now take a simpler "top-down" approach to the assessment, but they still have to assess any topic whose materiality isn't evident.⁴ Assurance stays at the limited level; the planned move to reasonable assurance has been dropped.⁵

02: Who reports, and when

Large groups only, from 2028

An EU company is now in scope only if it has more than 1,000 employees and more than €450 million net turnover. Listed SMEs are out entirely.⁶

Sources: Covington; Latham & Watkins.^{2, 5}

03: If you are a subsidiary of an EU group

Your numbers go into the group's report

An in-scope group reports on a consolidated basis, so its African subsidiaries supply the same data as its European ones. In practice, GCX expects requests to centre on:

• Climate (ESRS E1): energy use; Scope 1 emissions; Scope 2 emissions on both a location-based and market-based basis; and the Scope 3 categories that matter to the group.
• Own workforce (ESRS S1): headcount by gender and country, contract types, health and safety incidents, pay gap, collective bargaining coverage and training hours.
• Business conduct (ESRS G1): confirmed incidents of corruption.

The detail depends on what the group's own materiality assessment finds material. Timing matters more than the list. A group reporting on its 2027 financial year needs 2027 data from you, collected to a standard an auditor can check. That means systems in place during 2026 and 2027, not a scramble in 2028.

04: If you supply an EU group

The new value-chain cap protects you

The Omnibus introduced a cap on what reporting companies can demand from their value chain for CSRD purposes. Where a supplier or partner has up to 1,000 employees, the requester cannot ask for more than the EU's Voluntary SME Standard (VSME) sets out.⁵

The VSME was adopted as Delegated Regulation (EU) 2026/1560 and took effect on 24 September 2026. The cap applies from 1 January 2027.³ EFRAG's version of its basic module covers:⁷

• energy use and Scope 1 and 2 emissions
• pollution, biodiversity, water, resource use and waste
• workforce characteristics, health and safety, pay, collective bargaining and training
• convictions for corruption and bribery

The cap covers CSRD-driven requests only. A customer can still put sustainability terms into a commercial contract, and other EU rules such as the Carbon Border Adjustment Mechanism (CBAM) set their own data requirements.

05: Due diligence: the CSDDD

Smaller in scope, and later

The CSRD's sister law, the Corporate Sustainability Due Diligence Directive (CSDDD), was also cut back. It now applies to EU companies with more than 5,000 employees and €1.5 billion worldwide turnover, and to non-EU companies with more than €1.5 billion EU turnover. In-scope companies must comply from 26 July 2029.^{2, 5}

Due diligence is now risk-based. Companies scope risks using information that is reasonably available, then look closer where harm is likely. They may ask business partners with fewer than 5,000 employees for information only when it cannot reasonably be obtained another way. The requirement to adopt a climate transition plan has been deleted, and EU-wide civil liability removed.²

For African suppliers to the largest European groups, expect targeted questions on human rights and environmental risk where a buyer sees exposure, rather than blanket surveys.

06: Already reporting under IFRS S1 and S2?

Much of the climate work carries over

Many African companies are adopting the ISSB's IFRS S1 and S2. The IFRS Foundation and EFRAG published joint interoperability guidance in May 2024. It found that a company meeting the ESRS climate requirements has only a very limited number of extra points to cover to also comply with ISSB climate disclosure.⁸ The revised ESRS also name ISSB, SASB and GRI as reference sources for company-specific disclosures.⁴

The overlap is greatest on climate. Social and governance data still need separate attention, and the 2024 guidance predates the revised ESRS, so check the detail as updated mappings appear.

07: What to do now

Five steps for 2026 and 2027

• Map your EU exposure. List the European parents, customers and investors who will ask for data, and whether your own group could cross the €450 million EU-turnover line.
• Get Scope 1 and 2 to audit standard. Every route above asks for them. Report Scope 2 both location-based and market-based.
• Build one VSME-aligned dataset. It caps what CSRD customers can ask of most suppliers, and answers the bulk of what a parent group needs.
• Reuse your IFRS S2 work. Align climate data collection once, for both ISSB and ESRS.
• Set your 2027 baseline now. Groups reporting on 2027 will want 2027 data. Collection has to be running before that year ends.

This article reflects the EU rules as published at 7 October 2026. It is general guidance, not legal advice. Member States are still transposing the Omnibus directive, and national rules may differ in detail.