What do CSRD and ESRS mean for the arts and creative industries?

Cultural institutions are currently facing a multitude of challenges, often complex and multifaceted. In a world where awareness of sustainability is constantly growing, institutions, organizations, and market participants in the arts and creative industries are also required to increasingly align their processes and procedures with ecological and social aspects.

The need to make sustainability measures transparent and to demonstrate their effectiveness is becoming increasingly urgent. Recent climate disasters and their consequences clearly demonstrate this. Since the European Union Green Deal in 2019 , economic actors have faced numerous demands, whether from the public, government agencies, or their own target groups – whose expectations are rising.

To meet these challenges, it is crucial to take the first step towards complying with the Corporate Sustainability Reporting Directive (CSRD) German Council for Sustainable Development (RNE) website now offers helpful information and a clearly structured overview of how these first steps can be implemented.

Guidelines, recommendations for action, fact sheets, explanatory videos, and support documents are also available for download on the German Sustainability Code resources comprehensively explain the measures that should be taken to effectively implement long-term goals related to the European Sustainability Reporting Standards (ESRS) . The focus is on practical solutions and guidance for implementing sustainability structures. It is a process that requires not only time but also commitment and foresight.

But don't worry! Every little step counts, and the sooner you start, the better prepared you'll be for the demands of the future. Let's embark on this journey together and discover how cultural institutions can navigate this new era of responsible business practices successfully and in compliance with standards.

CSRD regulation – What is it about?

The starting signal was given with the European Green Deal

The  European Green Deal was  agreed upon in 2019. Climate change and environmental destruction are existential threats to Europe and the world, and this groundbreaking step was intended to finally send a strong signal. With this deal, the EU aims to create the transition to a modern, resource-efficient, and competitive economy that

• emits no net greenhouse gases by 2050,
• their growth decouples from resource use,
• takes a pioneering role in the exploitation of new market opportunities,
• and creates a socially acceptable transformation.

The EU's associated measures will cost approximately €260 billion per year until 2030. The costs of inaction, however, are estimated to be significantly higher: at least €400 billion per year.

Climate policy makes perfect sense from an economic perspective as well. To ensure we can act quickly, the EU has established corresponding regulations and guidelines. Which brings us to the CSRD.

CSRD – The Sustainability Reporting Guideline for Companies

The CSRD (Corporate Sustainability Reporting Directive) establishes a clear obligation for sustainability reporting and precisely defines how companies should report their carbon footprint further development of the Non-Financial Reporting Directive (NFRD) , it defines which companies are required to produce sustainability reports and how these reports should be structured.

A total of 90 guidelines specify exactly where reporting must take place, on which topics, and within what timeframe this information must be provided.

A significant aspect is the review of the sustainability report by an auditor, although an in-depth audit is not required. The reporting obligation extends across the entire value chain and encompasses all internal and external resources that a company needs to achieve its objectives. A clear commitment to climate protection exists, particularly at the management and leadership levels.

For the reporting year 2025, a large number of corporations (the platform greenly estimates around 50,000 companies in Germany * ) are required to report – namely those that meet at least two of the following three criteria in two consecutive years:

• more than 250 employees
• more than 50 million euros in revenue
• Total assets exceeding 25 million euros

The so-called Omnibus Regulation of 26 February 2025 has now adjusted the scope of affected companies by raising the employee threshold to more than 1,000. On 3 April, the European Parliament approved the "Stop the Clock" this on 14 April 2025.

The Stop-the-Clock Regulation therefore entered into force on April 16, 2025, following its publication in the EU Official Journal. Its a whole – is still pending. A detailed analysis of the Omnibus Regulation is provided by Green Vision Solutions .

Listed small and medium-sized enterprises (SMEs) are to be completely excluded from the scope of the CSRD. Furthermore, SMEs are to be relieved of some of the burden by no longer requiring companies subject to CSRD reporting requirements to collect all information from SMEs for their own sustainability reporting.

It is important that the sustainability report be part of the management, business or financial report.

European Sustainability Reporting Standards (ESRS)

In the future, sustainability information will be presented in the management report in accordance with the EU's uniform reporting standards. In this context, the European Financial Reporting Advisory Group (EFRAG), commissioned by the European Commission, initially developed cross-sectoral standards (Set 1) and submitted them to the Commission at the end of November 2022. On July 31, 2023, the European Commission published the delegated act relating to Set 1 of the ESRS.

The European Sustainability Reporting Standards (ESRS) follow the CSRD and regulate sustainability reporting for companies in the European Union in detail to ensure comparability across years and groups. The standards are divided into four main areas with a total of 12 sub-points: General Standards, Environmental Standards (e.g., climate change, resource use), Social Standards (e.g., workforce issues), and Governance Standards.

A total of approximately 1,000 data points are planned, although not all of them are mandatory.

A dual materiality analysis identifies relevant topics for each company in order to develop appropriate concepts and measures. The process should be broad and involve stakeholders and employees. Defined key performance indicators (KPIs) should be integrated into the company's reporting and management systems to keep progress visible and actively work towards achieving the objectives.

The current cross-sectoral European Sustainability Reporting Standards (ESRS) can be found on the European Commission's website. *

EU Taxonomy Regulation

The EU taxonomy is the third link in the regulatory chain and classifies economic activities according to their sustainability in line with the EU strategy. Since 2022, these activities have been assessed based on the criteria of "climate protection" and "adaptation to climate change" .

Companies are required to explain in their sustainability reports how they contribute to the six environmental goals, including the protection of water resources and the promotion of a circular economy. The EU Taxonomy Navigator helps companies make climate-sensitive decisions, including those for cultural and educational institutions such as libraries and museums.

The regulation also includes a recommendation to conduct a risk analysis to identify potential risks and opportunities that may arise from climate change – such as extreme weather events.

What do CSRD and ESRS mean for the arts and creative industries?

In Germany, around 238,000 companies and freelancers shape the cultural and creative industries, which include architects, artists, musicians, filmmakers, and game developers. With approximately two million employees, this sector makes a significant contribution to the overall economic output and generated a turnover of €204.6 billion in 2023, representing 2.2 percent of Germany's total economic output.*

The cultural and creative industries comprise profit-oriented companies that are involved in the creation, production and distribution of cultural goods and services.

Sole proprietors, micro-enterprises and SMEs are NOT affected

The good news first: The vast majority of self-employed individuals and micro-enterprises have nothing to worry about. Since the Omnibus Regulation and the Stop-the-Clock rule, they, like small and medium-sized enterprises (SMEs), are completely excluded from the scope of the CSRD.

Museums and cultural institutions

Although museums and other cultural institutions and organizations are not directly required to report, stakeholders and funders can still request CSRD-like reporting. Furthermore, museums can be part of the value chain of another reporting entity as suppliers or partners.

• Energy use & transport, visitor mobility (E1 Climate change)
• Resource use & circular economy (re-use, re-cycle) (E5)
• Working conditions, diversity, work-life balance in the area of ​​employees (S1 company workforce) and workers in the value chain (S2)
• Knowledge transfer in line with the educational mandate, low-threshold access options such as free entry, inclusion (S4 consumers and end users)
• Corporate Culture & Political Engagement (G1 Corporate Management)

This list can be adopted analogously for German museums.

Museums, cultural institutions, and public sector bodies can choose to publish sustainability reports in accordance with the CSRD even without a legal obligation (e.g., as role models or social pioneers). EFRAG has SMEs that are not legally required to report but wish to do so on a voluntary basis .

The EU Taxonomy Navigator * helps cultural institutions to make environmentally friendly decisions; this includes libraries, archives, museums and cultural activities.

Art Trade

Art dealers, galleries and private sector actors in the art and creative industries may be directly affected by the directive if they meet two of the above-mentioned size criteria.

Gaming industry

Since these are generally capital-oriented private companies, the aforementioned threshold also applies here.

Overwhelmed with sustainability reporting? Here's how to get support!

Legal texts and guidance documents from the German Sustainability Code

Despite the Omnibus Regulation, the CSRD will likely still require over 15,000 companies in Germany to disclose their sustainability performance in accordance with the EU's uniform reporting standard. The German Sustainability Code website provides support to affected companies in meeting the CSRD requirements.

Guidance and practical guides show how to gradually develop internal structures, collect and process data, and ultimately publish it in compliance with the law.

Guidance from IZU/BIHK: 10 steps to sustainability reporting according to CSRD

The Bavarian Chamber of Industry and Commerce's (IHK) guidance document, in cooperation with the Environmental Business Information Center (IZU), supports companies in developing their sustainability reporting in accordance with the new CSRD directive and the European Standards for Sustainability Reporting (ESRS). It is intended primarily for affected companies, but also offers invaluable guidance to SMEs.

The guide includes an introduction to the requirements of the CSRD and ESRS, as well as a focus on establishing a strategic sustainability management system. It is structured into ten consecutive steps that can be applied flexibly depending on the user's level of knowledge.

Practical checklists make it easier to track tasks.

Professional advice from sustainability experts

Often, you're best off in the hands of experts. This is especially true for complex topics like CSRD and ESRS. Greenly is a company that specializes in helping other businesses achieve their sustainability goals and meet the corresponding reporting requirements.

This begins with an analysis of the current reporting structure and the identification of gaps in relation to the requirements of CSRD Reporting and ESRS.

A key aspect of greenly's support is the provision of user-friendly tools that enable companies to measure and report their emissions. These tools are designed to be intuitive, so even those in the creative industries who may have less experience with technical reporting can easily use them. By automating data collection processes, errors are minimized and the time required for reporting is significantly reduced.

Greenly places great emphasis on developing tailored strategies for each company. This means identifying the specific challenges a company faces, whether in the production of artworks, the operation of exhibition spaces, or in the field of digital design. Greenly offers workshops and training courses to inform employees at all levels about the importance and implementation of sustainability reporting.

This includes creating transparent and engaging reports that clearly demonstrate the company's commitment to sustainability. These reports can then be used as a communication tool to inform and inspire stakeholders.

Joachim Rodriguez y Romero

Owner and Managing Director of Kunstplaza. Publicist, editor, and passionate blogger in the field of art, design, and creativity since 2011. Successful completion of a degree in web design as part of a university program (2008). Further development of creativity techniques through courses in free drawing, expressive painting, and theater/acting. Profound knowledge of the art market through many years of journalistic research and numerous collaborations with actors/institutions from art and culture.

www.kunstplaza.de/