Progress of discussions on the ‘Content’ Directive project

As a reminder, this initiative aims to amend the scope of the CSRD so that only large entities (or parent companies of large groups) with more than 1,000 employees are required to prepare and publish a sustainability statement compliant with the ESRS standards.  

At the Council of the European Union level, the Presidency’s compromise text was made public on 17 April 2025. This text generally aligns with what was presented by the European Commission on 26 February 2025. However, it is notably proposed that Member States may be authorized to exempt wave 1 companies from publishing a sustainability report for 2026, for those that would no longer be subject to sustainability reporting requirements from the 2027 financial year, given the new scope of the CSRD (which remains to be confirmed) 

Despite the willingness of Member States to make rapid progress on the ‘Content’ Directive, discussions at the end of April on the Polish Presidency’s compromise text revealed divergences of views on important issues, particularly the scope of the CSRD. Several Member States are calling for even more ambitious changes than those proposed by the Commission, such as raising the turnover threshold to align with the CSDDD threshold (450 million EUR), or creating an additional category of “medium-sized” companies (for example, those with between 250 and 1,000 employees, and generating a turnover between 50 and 450 million EUR) that would communicate more limited information (for example, in accordance with the voluntary standard for SMEs (VSME)). 

At the European Parliament level, the draft report of the Legal Affairs Committee (JURI) will be presented at the end of June. The committee vote on this report is scheduled for 13 October 2025, ahead of the plenary session starting on 20 October 2025. In the meantime, tough negotiations are expected, with initial discussions in late April revealing significant differences of opinion between the various political groupings in Parliament. 

 Against this backdrop, the provisions and final wording of the ‘Content’ Directive will depend on the Trilogue negotiations, which are expected to take place in early November at the earliest.