The situation
The group’s size, structure and listing status
A Dutch group owns a regional heat network, a solar developer and a services company, with subsidiaries in Belgium and Germany. It is not listed. The auditors asked whether it is within the sustainability reporting rules, and the CFO has heard three different answers since the EU started changing them.
The scope has moved more than once: first delayed, then amended. The hours go on establishing what is in force today, how the size tests apply at entity and group level, whether a subsidiary exemption helps, and what the Dutch implementing law says.
What the research has to settle
The rules behind the answer
- Scope is set by size, listing and structure
- The Corporate Sustainability Reporting Directive applies by reference to company size, listed status and group structure. Size is tested on employees, turnover and balance sheet, for single companies and for groups on a consolidated basis.
- The scope and dates have been changed
- The EU postponed the later reporting waves in 2025 and has since worked on narrowing the scope. The thresholds and first reporting years that apply today are what the research has to confirm before anyone relies on them.
- Subsidiaries can rely on a group report
- A subsidiary can be exempt from its own report where it is included in a parent’s consolidated sustainability report that meets the directive’s conditions on content and publication.
- National law decides the detail
- The directive applies through national law. The research confirms the status of the Dutch implementing act and, for the Belgian and German subsidiaries, their own national rules.
How it runs in azta
From the question to the document
The question, as you would type it
Unlisted Dutch group: heat network, solar developer and services company, with subsidiaries in Belgium and Germany. About 900 employees and EUR 380 million consolidated turnover. Are we within CSRD scope as it stands today, from which financial year, and at which level?
You start with
The group’s size, structure and listing status
- 01
Describe the group
Give each company, its country, employees, turnover and balance sheet. azta searches the directive, the amending acts and the Dutch implementing legislation.
Cited research· Free - 02
Compare the versions
Open the scope provisions in the reader and compare versions to see what the amendments changed and from when.
Atlas statute reader - 03
Draft the board memo
Ask for a memo with the question, the law in force today, the result for each company and the open points. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Export for the board and auditors
Export the memo to Word and keep the cited research for the auditors.
Word export· Pro You send
A memo on whether, from when and at which level the group must report
What you get
A memo on whether, from when and at which level the group must report
Board memo · draft
Sustainability reporting: is the group in scope
Question. Must the group, or any company in it, publish a sustainability report under the Corporate Sustainability Reporting Directive, and if so from which financial year?
Current law. The answer depends on the scope as amended, not as first adopted. Annex 1 sets out the size tests and dates in force on the date of this memo, with the provisions, and applies them to the group’s figures for the last two financial years.
Subsidiaries. If the group is in scope at consolidated level, the Belgian and German subsidiaries may be exempt from their own reports through the group report. If it is not, we will confirm whether any subsidiary is in scope on its own figures under its national law.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
12 minutes a month
At €140 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 22
- Capacity at your rate
- €3,024
- More reporting-scope memos a quarter
- 0.8
- Return on Pro
- 9.3×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoSources azta searches here
- EUR-Lex · Curia
- wetten.overheid.nl
- Justel
- Gesetze im Internet
What stays with you
- The group’s figures and the consolidation.
- The decision on any voluntary reporting.
- Agreeing the position with the auditors.
Frequently asked questions
- Does azta know about the latest amendments?
- Legislation is indexed daily, and each citation shows whether the provision is in force on the date you ask about. Compare versions in the statute reader to see what changed.
- Does it cover the reporting standards?
- It holds EU legislation, including the delegated acts that adopt the standards. It does not prepare the report or decide what is material for you.
- Can it cover the taxonomy and due diligence rules too?
- Yes. Ask separately. azta researches each instrument’s own scope, which is not the same as the reporting scope.
