Belgian government fails to meet SRDC deadline

Belgian government fails to meet SRDC deadline

August 2024 - The CSRD requires companies to report on their human and environmental impact from 2024. Unfortunately, the Belgian government has failed to meet the deadline for transposing this directive into national legislation.

In spring 2024, the deadline for the first CRSD report was set... Companies subject to the CSRD reporting obligation must start preparing for this obligation in good time.

The Corporate Sustainability Reporting Directive (CSRD) provides companies with a standardised framework for measuring and reporting their environmental, social and governance (ESG) impacts... By promoting transparency, the CSRD helps companies take responsibility for their actions and inform stakeholders about their efforts in the area of sustainable development. This fosters trust and loyalty among customers, investors and other stakeholders. It also stimulates competitiveness and innovation.

Which companies are attracting the most attention?

·       Are you a listed company (large enterprise) or a public interest company? Then the 2025 report on the 2024 financial year applies.

·       Are you a large company (net sales > €50 million and/or balance sheet total > €25 million and/or > 250 employees)? Then take into account the declaration in 2026 for the 2025 financial year.

·       Are you a listed SME? If so, the declaration in 2027 for the 2026 financial year applies.

·    Are you (as an SME) part of the ecosystem (as a supplier, customer, partner, etc.) of a company belonging to the first three categories? Your efforts will then be taken into account in their report.

The complex process of identifying materiality

The process of identifying materiality in CSRD sustainability reports involves an in-depth analysis of internal and external factors to determine the key sustainability issues affecting the company and its stakeholders. This includes identifying environmental issues, social impacts and governance practices relevant to the company's activities and stakeholders, and then developing targeted strategies to address them.

The whole process of identifying these materialities - including converting them into actions and processes with demonstrable data KPIs - is both lengthy and complex. This cycle can last from six to eight months.

July 2024 deadline missed

More than 2,000 Belgian companies will have to wait longer than expected for a definitive roadmap to report on the sustainability of their activities and the efforts they are making to improve them. The reason? The Belgian federal government failed to meet the deadline of 6 July 2024 (for transposing the European CRSD directive into national law). As a result, Belgian companies have had to continue drawing up their reports in accordance with existing national guidelines rather than the new European standards...

This situation creates a great deal of uncertainty for Belgian companies, as they have had to continue to comply with the current standards while preparing for the stricter requirements that will come into force later. In particular, there is still ambiguity as to how the new sustainable development reports will be monitored. The draft bill provided for the reports to be monitored by an auditor for the first three years, after which other parties, such as an auditor, could also be responsible.

The fact that Belgium has not adopted the CSRD law does not mean that companies are completely blind when it comes to their environmental reports. In any case, the Belgian government is working on a plan to implement the new legislation as soon as possible, but recognises that there are significant challenges ahead.