CSRD Reporting for Financial Advisers and Insurance Brokers
The Corporate Sustainability Reporting Directive (CSRD) is reshaping how financial advisers, insurance brokers and other financial intermediaries communicate their environmental and social impacts. Far from being an abstract compliance exercise, this new framework connects sustainability disclosure to business resilience, investor trust, and client relationships in the financial services sector.
This guide explains how financial advisers, insurance brokers, and other small financial firms can prepare for CSRD and use the Voluntary Sustainability Reporting Standard for SMEs (VSME) to meet growing disclosure expectations. Most financial SMEs are office-based, so also review guidance on CSRD for office SMEs.
1. Why CSRD Matters for Financial Intermediaries
The financial sector is central to Europe’s sustainability transition. Under the EU’s Green Deal and Action Plan on Financing Sustainable Growth, finance professionals are expected to channel capital toward sustainable activities while managing environmental, social and governance (ESG) risks.
CSRD extends reporting duties to:
- Large undertakings and listed SMEs, including credit institutions and insurance undertakings meeting size thresholds.
- Non-listed SMEs that provide sustainability information voluntarily, often to meet client, investor, or banking requests.
Even if your firm is not directly in scope, your clients and counterparties — such as investment managers or insurers — will request ESG data from you to meet their own reporting obligations.
2. Who Must Report and When
| Type of Entity | Typical Examples | Reporting Requirement | First Reporting Year |
|---|---|---|---|
| Large financial institutions | Banks, large insurers | Mandatory CSRD (using ESRS) | 2025 (for FY 2024) |
| Listed SMEs | Listed financial advisers or brokers | Mandatory CSRD (proportionate) | 2027 (for FY 2026) |
| Non-listed SMEs | Most independent financial advisers, brokers | Voluntary (VSME) | Optional now – recommended before 2026 |
Size thresholds (CSRD definition)
An undertaking is large if it exceeds two of the following:
- €25 million balance sheet total
- €50 million net turnover
- 250 employees
Most independent financial advisers and insurance brokers fall below these thresholds — but they may still report voluntarily under VSME to satisfy banks, insurers or clients.
3. What Financial Advisers and Brokers Must Disclose
3.1 Environmental Data
Even small advisory firms consume energy and travel for client meetings. Under VSME Basic Module B3, SMEs are asked to report:
- Energy use from electricity and heating (from bills)
- Scope 1 and 2 greenhouse gas (GHG) emissions
- GHG intensity (emissions divided by turnover)
Quick Win: Use your annual electricity, gas and travel invoices to calculate energy use. Many national sustainability agencies provide free online calculators for SMEs.
3.2 Social Data
The VSME Basic Module B8–B10 covers workforce data:
- Number of employees and gender distribution
- Work-related accidents (even if zero)
- Pay equity and training hours
For small advisory firms, focus on fair pay, training, and equal opportunity disclosures.
3.3 Governance and Conduct
Given the fiduciary role of advisers and brokers, governance disclosures are especially important:
- Anti-corruption and bribery policies (B11)
- Data protection and client trust practices
- Complaints handling and ethical codes (C6–C7 in the Comprehensive Module)
If your firm is authorised under MiFID II or the Insurance Distribution Directive (IDD), much of this information already exists in compliance documentation.
4. Reporting Tools and Frameworks
Use of the VSME Standard
The VSME Basic Module provides a ready-to-use structure for small financial undertakings:
- B1–B2: General information and sustainability practices
- B3–B11: Key metrics on energy, social and governance issues
You can complete the Basic Module in 1–2 days with existing data (bills, payroll, HR records). If clients or investors request more depth, add selected Comprehensive Module disclosures (e.g., climate targets, human rights, gender diversity).
Data Sources for Financial Firms
| Disclosure Area | Typical Data Source |
|---|---|
| Energy use | Office energy bills or landlord data |
| Travel emissions | Mileage logs or travel booking records |
| Workforce data | Payroll and HR records |
| Governance | Existing compliance policies and procedures |
Tip: Store evidence (bills, reports, policies) for at least five years in case an assurance or client audit is required.
5. Double Materiality for Financial Intermediaries
Under CSRD, companies must assess both impacts and risks — a concept known as double materiality.
For financial advisers and brokers, key examples include:
- Financial materiality: climate-related risks affecting investment portfolios or insurance underwriting.
- Impact materiality: your influence on sustainable investment flows, client awareness, and product suitability.
Even if your own operations are low-impact, your advisory influence has a strong indirect sustainability footprint.
6. Integration with Other EU Rules
Financial and insurance intermediaries already face overlapping EU obligations:
- SFDR (Regulation 2019/2088) – requires ESG disclosures for financial products.
- EU Taxonomy (Regulation 2020/852) – defines sustainable economic activities.
- CSRD – standardises how entities report sustainability information at company level.
CSRD ensures alignment with SFDR and the Taxonomy by requiring disclosures that investors and insurers can use directly.
7. How to Get Started
Step 1 — Map Your Data
List what you already collect for compliance (e.g., AML, IDD, SFDR). Many data points overlap with VSME reporting.
Step 2 — Select Your Module
Most small financial firms start with the VSME Basic Module; larger or network-affiliated firms may add the Comprehensive Module for investor readiness.
Step 3 — Assign Responsibility
Nominate one team member (often compliance or operations) as your sustainability coordinator. No dedicated sustainability officer is required.
Step 4 — Publish or Share
Decide whether to share your sustainability statement:
- Privately with banks or corporate clients, or
- Publicly (e.g., on your website or annual brochure)
8. Example Summary Table for a Small Financial Firm
| Area | Example Disclosure | Data Source |
|---|---|---|
| Energy | 8 MWh total (100% from renewable provider) | Electricity bills |
| Workforce | 10 employees, 60% women | HR records |
| Governance | 0 fines, 100% staff trained on ethics | Compliance log |
| Policies | ESG investment policy updated 2025 | Firm documentation |
9. Benefits Beyond Compliance
- Access to green finance: Banks increasingly require sustainability data for lending decisions.
- Client trust: Retail investors value ESG transparency from their advisers.
- Operational efficiency: Tracking energy and waste often identifies cost savings.
Frequently Asked Questions
Do financial advisers and insurance brokers need to report under CSRD?
Most small financial advisers and insurance brokers are not directly required to report under CSRD, which applies to large companies (250+ employees, €40M turnover, or €20M assets). However, many financial firms need to provide sustainability data to banks, corporate clients, or regulatory bodies who are CSRD-compliant. The VSME Standard offers a simplified, voluntary framework for financial firms to meet these requirements efficiently.
Check if CSRD applies to your business →
What are the most important CSRD topics for financial advisers?
The key topics for financial advisers are: (1) energy use and emissions from offices (VSME B3), (2) workforce diversity and training (VSME B8-B10), (3) governance and ethics including anti-corruption policies (VSME B11), and (4) financed emissions if you provide investment advice (Scope 3). These align with the CSRD’s focus on environmental and social impacts and are most relevant to financial services operations.
How do I report financed emissions if I’m a small adviser?
For small advisers, financed emissions (emissions from investments you recommend) are typically reported under Scope 3 if material. However, for VSME Basic Module, you can focus on your direct operations (energy, workforce, governance) and note that financed emissions are addressed through your ESG investment policies. Larger firms or those with significant investment portfolios may need to report financed emissions in more detail.
Learn about financed emissions →
Can I use existing compliance data for CSRD reporting?
Yes! You can reuse data from your MiFID II, IDD, or SFDR compliance documentation, AML procedures, HR records, and any existing environmental management systems. The VSME Standard is designed to work with data you’re already collecting for regulatory compliance. Just organise your existing compliance data into the VSME Basic Module format (B1–B11) for your sustainability report.
Key Terms
- CSRD: EU Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464).
- VSME: Voluntary Sustainability Reporting Standard for non-listed SMEs (EFRAG, 2024).
- Basic Module: Core sustainability disclosures (B1–B11).
- Comprehensive Module: Optional extended disclosures (C1–C9).
- ESRS: European Sustainability Reporting Standards for large undertakings.
- SME: Small and medium-sized enterprise.
- Scope 1 and 2 emissions: Direct and indirect energy-related greenhouse gas emissions.
- Turnover: Total revenue generated during the financial year.
