A Slow Implementation
As companies operating in the European Union ("EU")
likely now know, new environmental, social, and governance
("ESG") regulations are set to have a significant impact
on disclosure and governance obligations for EU and non-EU
companies alike. Some of these new obligations include extensive
sustainability reporting and due diligence requirements on
potentially highly sensitive and detailed ESG matters, including as
related to climate risks.
The EU Corporate Sustainability Reporting Directive 2022/2464
("CSRD") will impose significant new reporting
obligations on "large" EU companies and groups of
companies with an EU subgroup parent company starting now and, in
2029, will require reporting from non-EU companies doing business
in the EU for FY2028 information. Currently, most subsidiaries and
subgroups of U.S. and other non-EU parent companies are expected to
have to report in 2026 for FY2025 information. This includes groups
and subgroups of