The Corporate Sustainability Reporting Directive (CSRD) marks a decisive turning point for companies in terms of transparency on their environmental, social and governance (ESG) practices. Its broader scope raises a crucial question for organizations, particularly in the real estate sector: “Am I concerned by CSRD reporting? Whether you’re a social landlord, a property manager or a company with offices, this directive could have a major impact on your ESG reporting obligations.
1. Who is concerned by the CSRD?
The CSRD is gradually replacing the Non-Financial Reporting Directive (NFRD), imposing stricter obligations and a broader scope of application. From 2024, several criteria will define the companies subject to this directive:
- Large companies: Any European organization exceeding two of the following three thresholds:
- More than 250 employees.
- Annual sales in excess of 40 million euros.
- Total assets in excess of €20 million.
- Listed companies: All listed companies, regardless of size.
- Companies operating in sectors with a significant impact on the environment: Real estate, in particular, is identified as one such sector, due to the significant environmental impact associated with the management of buildings, material resources and energy consumption.
Companies that do not yet meet these criteria will be progressively integrated, with listed SMEs included from 2026.
2. Impact on the real estate sector
In the real estate sector, whether you’re an asset manager, a real estate company or a player in the construction industry, you’re particularly concerned by the CSRD because of your environmental footprint and the management of building-related resources. Several aspects are directly impacted by this new directive:
- Building inventory and management: The CSRD requires reporting not only on companies’ carbon emissions, but also on the impact of their real estate infrastructure (buildings, offices, warehouses, etc.). A company owning or managing a large real estate portfolio will therefore need to keep a close eye on the carbon footprint of these assets.
- Circular economy: The directive encourages the reuse of materials and the minimization of waste. Real estate players must implement practices that maximize circularity in renovation or construction projects, in order to comply with European sustainability objectives.
- Energy consumption and efficiency: As owners of office or commercial buildings, you need to document energy consumption and identify ways of improving energy efficiency.
These factors show that companies with large real estate holdings, even outside the construction sector, are affected.
3. The specific case of social landlords
Social landlords are also concerned by CSRD, due to their massive property management and social mission. Here’s why:
- Size and importance of building stock: Many social landlords manage thousands or even tens of thousands of homes. This impact in terms of building management, resource use and energy consumption brings these organizations directly within the scope of the CSRD.
- Obligations in terms of energy rehabilitation and renovation: Social landlords are already subject to strict requirements on the thermal renovation of buildings. The CSRD adds a further layer of transparency, requiring reporting on the carbon footprint of their real estate activities, including materials and infrastructure management.
- Social role and greater transparency: As players with a social mission, social landlords will also have to meet the CSRD’s expectations on social criteria, guaranteeing housing quality, equitable access and respect for tenants’ rights.
For social landlords, complying with the CSRD is more than just meeting regulatory requirements: it also demonstrates their commitment to sustainable, responsible property management.
4. Which ESG criteria should be monitored?
The CSRD is based on specific reporting standards, known as ESRS (European Sustainability Reporting Standards), which cover various ESG-related aspects. Here are the main areas on which real estate companies, including social landlords, must focus:
- ESRS E1: Climate change: carbon impact of buildings, emissions reduction, monitoring energy consumption and energy efficiency efforts.
- ESRS E5: Circular economy: traceability of materials, use of sustainable resources, reuse of materials in renovations or new construction.
- ESRS S2: Working conditions and human rights: Transparency in managing relations with tenants (in the case of social landlords), respect for living and working conditions in construction or rehabilitation projects.
- ESRS E4: Biodiversity: Impact of construction or property management activities on surrounding biodiversity, particularly in new real estate projects.
5. How to prepare?
If you’re affected by CSRD, it’s essential to start structuring your compliance efforts now. Companies will need not only to collect data, but also to automate and standardize their reporting to meet CSRD requirements. Upcyclea Reporting offers tailored solutions to support real estate companies in this transition. Thanks to itsbuilding inventory capabilities and circular economy-compliant materials management, our tool enables :
- Trace the materials used in real estate projects, facilitating their reuse or recycling.
- Calculate carbon emissions linked to real estate assets, including offices, social housing and other assets.
- Optimize energy efficiency by centralizing building energy consumption data to produce CSRD-compliant reports.
Conclusion: Am I subject to CSRD?
Whether you’re a social landlord, a company with offices or a major player in the real estate sector, the answer is most likely yes. CSRD imposes strict obligations on any company with a significant impact on the environment and society. Real estate, whether in terms of building management or materials, is a major component of this reporting. By preparing now for these new requirements, companies can not only ensure compliance, but also seize the opportunity to become leaders in sustainability and responsible real estate management.
