CSRD Reporting in Italy: Who Reports and How to Respond

Introduction

The Corporate Sustainability Reporting Directive (CSRD) is the European Union’s law on sustainability reporting. Italy transposed it through Legislative Decree no. 125/2024 (D.Lgs. 125/2024), published in the Gazzetta Ufficiale on 6 September 2024, which amended the Italian Civil Code and the Consolidated Law on Finance (TUF). CONSOB (Commissione Nazionale per le Società e la Borsa) supervises the resulting disclosures by listed companies, with assurance provided by registered statutory auditors overseen by the Ministry of Economy and Finance.

Since the Omnibus I simplification took effect on 18 March 2026, CSRD applies only to the largest companies: those with more than 1,000 employees and net turnover above €450 million. Most Italian businesses are below that line and are not required to file. They are, however, increasingly asked for environmental and social data by the in-scope companies and banks they work with.

This guide serves two readers:

• If your company is in scope, jump to the in-scope path for what a CSRD report requires in Italy.
• If you are a supplier or smaller business asked for ESG data, go to the supplier path and the Voluntary Sustainability Reporting Standard for SMEs (VSME).

Who reports under CSRD in Italy

Under D.Lgs. 125/2024, as amended by Omnibus I, a company is in mandatory scope only if it meets both of these tests:

• more than 1,000 employees, and
• net turnover above €450 million.

A few points follow from this:

• Mid-sized companies (250–1,000 employees) are no longer in scope. Omnibus I removed them.
• Listed SMEs are no longer in scope. The separate listed-SME reporting track has been eliminated.
• Smaller and sub-1,000-employee companies are not CSRD filers. They may still receive ESG requests from larger clients and banks, which they answer through VSME rather than a CSRD report.
• A non-EU parent can be caught where it has more than €450 million of EU turnover plus a sufficiently large Italian subsidiary or branch.

In-scope companies report against the European Sustainability Reporting Standards (ESRS), the detailed rules issued under CSRD. VSME is a separate, voluntary standard and is not part of the ESRS.

If your company is in scope

If you cross the 1,000-employee and €450 million thresholds, your obligations run through the ESRS:

• Double materiality. You assess each topic for both impact materiality (your effect on people and the environment) and financial materiality (its effect on your business). A topic is reported if either is significant. Under the simplified ESRS, only the cross-cutting ESRS 2 general disclosures are mandatory for everyone; the topical standards (climate E1 through business conduct G1) are included only where your assessment flags them as material.
• The topical standards. These cover climate change, pollution, water, biodiversity, resource use, your own workforce, value-chain workers, affected communities, consumers, and business conduct. Climate disclosure under E1 includes Scope 1, 2 and 3 greenhouse gas emissions.
• Limited assurance. From the first reporting year, a registered statutory auditor provides limited assurance that the data is plausible, traceable and consistent. In Italy this sits under CONSOB oversight for listed companies and the Ministry of Economy and Finance.
• Timeline. Large public-interest entities already inside the old NFRD regime continue to report. Other large companies that now meet the threshold report on financial years starting on or after 1 January 2027, after the two-year deferral introduced by the Stop-the-Clock Directive (EU 2025/794).

If you are early in this, the overview of what CSRD reporting involves is a useful starting point before scoping a full ESRS exercise.

If you’re a supplier asked for ESG data

Most Italian businesses meet CSRD not as filers but as suppliers. A large customer, an export buyer, or a bank assessing a loan asks for environmental and social figures, because that data feeds their own CSRD report or their ESG lending criteria. You do not need to produce a CSRD report to answer. The proportionate route is the Voluntary Sustainability Reporting Standard for SMEs (VSME), developed by EFRAG for exactly this purpose.

There is also a legal limit on what they may ask. Since Omnibus I, a CSRD reporter cannot require more sustainability information from a partner with fewer than 1,000 employees than the voluntary SME standard defines, a ceiling the European Commission fixed in a delegated act adopted on 3 July 2026. Our guide to what large customers can ask suppliers explains the cap and its limits.

VSME comes in two levels:

• Basic Module – the core disclosures most smaller businesses are asked for: energy, emissions, workforce data, waste, and governance basics.
• Comprehensive Module – a more detailed version covering climate targets, risks, and human rights, which banks or large corporate clients sometimes request.

For most Italian suppliers, starting with the Basic Module is the practical choice.

What the Basic Module covers

1. General information – legal form (e.g. Srl, Snc), ATECO sector code, turnover, number of employees, country of operations.
2. Energy and emissions – total annual energy use (from utility bills), Scope 1 emissions (fuel used in company vehicles or boilers), Scope 2 emissions (electricity and heating).
3. Pollution – only if the business is already legally required to declare pollutants.
4. Biodiversity – disclose if sites are in or near protected or sensitive natural areas.
5. Water – total water use, particularly in high water-stress areas.
6. Waste and circular economy – total waste generated, proportion recycled or reused, and use of circular practices.
7. Workforce – employee numbers by contract type and gender, turnover rate, training hours, gender pay gap (if applicable).
8. Health and safety – number of workplace accidents and fatalities.
9. Governance – any convictions or fines related to corruption or bribery.

Practical steps

• Start with existing records – utility bills, payroll data, and waste invoices often cover much of what is needed.
• Use a simple system – an Excel or Airtable sheet can be enough to collect figures once per year.
• Work through the Basic Module as a checklist – even if a topic is not relevant, mark it as “not applicable” rather than leaving it blank.
• Get support where needed – your accountant (commercialista) or industry association may help.
• Reuse your answers. The same energy, water and payroll figures tend to come back each time a customer or bank asks. Keeping them in one place, such as an ESG answer bank, means you answer the next request by reusing what you already prepared rather than starting again.

Italian large companies most often ask suppliers for energy and emissions data (ESRS E1), waste and materials (E5), and workforce information (S1). Sectors with strong export markets such as fashion, food, furniture and machinery also see supply-chain traceability requests from international clients. Italy is also ahead of most of Europe in adopting VSME as the request format: chamber-of-commerce tools and bank-linked platforms such as Open-es and Synesgy increasingly collect supplier data in VSME structure, so a VSME-shaped answer travels well. Answering early signals transparency and readiness, and much of the data is already in your hands.

Frequently Asked Questions

Which Italian law transposed CSRD?

Italy transposed CSRD through Legislative Decree no. 125/2024 (D.Lgs. 125/2024), published in the Gazzetta Ufficiale on 6 September 2024. It amended the Italian Civil Code and the Consolidated Law on Finance (TUF) to integrate CSRD disclosure obligations. Because the decree implements the EU directive, later EU changes flow through: the Stop-the-Clock measure (EU 2025/794, April 2025) deferred reporting dates, and the Omnibus I simplification directive (in force 18 March 2026) raised the mandatory scope thresholds and removed mid-sized companies and listed SMEs.

Who supervises CSRD compliance in Italy?

CONSOB (Commissione Nazionale per le Società e la Borsa) oversees disclosures by listed companies, while non-listed businesses report through the Chamber of Commerce (Camera di Commercio). Assurance is provided by registered statutory auditors, overseen by the Ministry of Economy and Finance.

Do smaller Italian suppliers have to file a CSRD report?

No. Companies below the 1,000-employee and €450 million thresholds are not CSRD filers. When a large customer or bank asks them for sustainability data, they answer through the voluntary VSME standard rather than producing a full CSRD report against the ESRS.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law requiring large companies (more than 1,000 employees and net turnover above €450 million) to report on environmental and social impacts. Following the 2026 Omnibus I simplification, mid-sized companies and listed SMEs are no longer in scope. SMEs are not in scope but may be asked for CSRD-style data by larger clients and banks.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified EU framework to help SMEs share sustainability data. Voluntary, but useful when banks or customers request information.
• Basic Module — The minimum reporting set in VSME, covering energy, emissions, waste, workforce and governance.
• Comprehensive Module — A more detailed version of VSME, including climate targets, risks and strategy. Often requested by banks or large clients.
• European Sustainability Reporting Standards (ESRS) — Detailed reporting rules for large companies under CSRD. VSME is a separate, voluntary standard for SMEs and is not part of the ESRS.
• SME (Small and Medium-sized Enterprise) — A company with fewer than 250 employees, turnover under €50m, or balance sheet total under €25m.
• Scope 1 and Scope 2 emissions — Scope 1 are direct emissions from fuel or company vehicles; Scope 2 are indirect emissions from purchased energy such as electricity or heating.
• Turnover — Total income from normal business activities in one year.