The year 2023 marks an important turning point in the field of sustainability with the entry into force of new obligations for businesses, including:
- The European CBAM Regulation – Carbon Border Adjustment Mechanism, (EU) 2023/956 of 10 May 2023, which provides for a transitional period for the application of the CBAM (Carbon Border Adjustment Mechanism) in force from 01 October 2023 to the end of December 2025, during which EU importers of materials included in the list annexed to the regulation must comply with the new environmental compliance requirements, observing the reporting obligations provided for in Articles 34 and 35 thereof. The first quarterly CBAM report must be submitted by 31 January 2024. This mechanism, by applying a carbon price to products imported into the Union according to a list of products established by the legislation, will lead to the gradual elimination of free allowances in the EU emissions trading system by 2034.
- The so-called CSRD Directive, No. 2022/2464, published on 16 December 2022 in the Official Journal of the EU, progressively extends the obligation for corporate sustainability reporting (Corporate Sustainability Reporting Directive – CSRD) ESG, requiring Member States to transpose it within 18 months from the date of publication. This directive provides for an audit of the truthfulness of the information contained therein (carried out by an accredited third party), must be available in digital format involving the use of digital validation tags, must be included in the Annual Management Report and must adopt a single reporting standard ESRS (European Sustainability Reporting Standard). The progressive extension of these obligations will apply from 1 January 2024 to large public-interest undertakings (with more than 500 employees) already subject to the non-financial reporting directive, with publication of data due in 2025; from 1 January 2025 to large undertakings not yet subject to the non-financial reporting directive (with more than 250 employees and/or EUR 40 million in turnover and/or EUR 20 million in total assets), with the deadline in 2026; from 1 January 2026 to SMEs and other listed companies, with the deadline in 2027. SMEs may choose not to participate until 2028.
- The Delegated Regulation 2021/2178 on the European Taxonomy also falls within these obligations for the harmonisation of extra-financial reporting, establishing different disclosure obligations for the economic activities carried out by financial and non-financial undertakings, for the purposes of the disclosure obligations to be included in the NFS, which from 1 January 2023 will include information relating to all climate objectives. They are used to assess the sustainability of the activities carried out by undertakings, ensuring that they do not cause significant harm to the environment (DNSH principle – Do No Significant Harm).
In order to support Companies in progressively addressing the pursuit and development of sustainability, CSIA offers a range of high value-added services:
- Preparation of the non-financial statement in compliance with the disclosure obligations linked to the company’s eco-sustainable activities.
- Support in the preparation of the quarterly CBAM report: calculation of embedded emissions in goods imported into Europe using various methods (e.g. full reporting, reporting based on equivalent national systems of third countries, reporting based on default values, etc.) mentioned in Article 4 of the Implementing Regulation. From 1 January 2025, however, only full reporting methods will be accepted, namely those provided for in Article 4 of the Implementing Regulation (see also p. 10 of the “Guidance document on CBAM installations for importers of goods into the EU”): the “calculation-based” approach, which uses the quantities of all fuels and materials consumed and the corresponding “calculation factors” (in particular the so-called “emission factor” based on the carbon content of the fuel or material), and the “measurement-based” approach, which involves measuring the concentration of greenhouse gases and the flue gas flow for each emission source.
- Carrying out a sustainability diagnosis: analysis of the internal and external context to measure the Company’s degree of compliance with the new requirements introduced by the CSRD and ESRS standards and assessment of its positioning compared with direct competitors.
- Annual training plan, webinars, … to align specific and diversified technical-organisational skills (sustainability experts, legal professionals, HR professionals, operations experts, IT specialists, etc.), according to the specific needs of the business sector or market segment/target.
- Sustainability due diligence: in order to also include information on material impacts, risks and opportunities connected with the entire upstream and downstream value chain, we support companies in carrying out the delicate activities of due diligence and materiality analysis.
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