CSRD: Why Some U.S. Companies Still Need to Track EU Sustainability Reporting Rules

The European Union’s Corporate Sustainability Reporting Directive, known as CSRD, continues to matter for U.S. companies with significant European operations. The rule is not aimed only at European companies. Certain non-EU parent companies, including U.S.-based companies, can still be required to report if their EU activity is large enough. The key issue is not where the company is headquartered; it is whether the company has enough EU revenue and an EU subsidiary or branch that meets the reporting threshold. Recent EU simplification changes narrowed the scope, but did not eliminate reporting for large non-EU companies. 

Under the revised scope, a non-EU parent company may be covered if it has more than €450 million in net turnover generated in the EU and has an EU subsidiary or branch generating more than €200 million in turnover. This is a major increase from the earlier threshold, which was generally discussed as €150 million in EU turnover and a smaller branch/subsidiary threshold. The practical effect is that fewer U.S. companies will be directly covered, but large U.S. companies with major EU operations still need to evaluate whether they are in scope. 

For CPAs, financial advisors, controllers, and investment professionals, the lesson is simple: CSRD is a financial risk and reporting-readiness issue. Even when a U.S. company is not directly required to report, it may still be asked for sustainability-related information by European customers, lenders, insurers, investors, or supply chain partners. Sustainability information is increasingly used in due diligence, procurement, financing, risk review, and long-term investment analysis.

EU Revenue Detail for U.S. Companies

CSRD QuestionCurrent Practical ThresholdIs the company a non-EU parent company?Applies to U.S.-based parent companies if EU activity is large enoughEU net turnover thresholdMore than €450 million generated in the EUEU subsidiary or branch thresholdMore than €200 million turnoverFirst reporting period for qualifying non-EU parent companiesGenerally financial year 2028First report publicationGenerally 2029Reporting standardEuropean Sustainability Reporting Standards, or ESRS

U.S. Companies That May Need to Comply

A definitive public list of U.S. companies that must comply should not be published without confirming each company’s EU net turnover, EU subsidiary structure, and branch/subsidiary turnover. Many U.S. companies do not clearly disclose EU turnover in the exact format needed for CSRD scoping.

However, the following types of U.S. companies should be reviewed carefully because they commonly have significant EU operations:

Company TypeExamples to Review for CSRD ScopeLarge technology companiesApple, Microsoft, Alphabet, Amazon, Meta, Salesforce, Oracle, IBMLarge consumer product companiesCoca-Cola, PepsiCo, Procter & Gamble, Colgate-Palmolive, NikeLarge pharmaceutical and healthcare companiesJohnson & Johnson, Pfizer, Merck, Eli Lilly, Abbott, MedtronicLarge industrial and manufacturing companiesCaterpillar, Honeywell, 3M, General Electric, Deere & CompanyLarge food and restaurant companiesMcDonald’s, Starbucks, Mondelez, Kraft HeinzLarge financial institutionsJPMorgan Chase, Bank of America, Citigroup, Goldman Sachs, Morgan StanleyLarge retail and logistics companiesWalmart, Costco, UPS, FedEx

These companies should not be labelled as “confirmed required” unless their EU revenue and subsidiary/branch data meet the final CSRD thresholds. The accurate statement is:

Large U.S. companies with more than €450 million in EU net turnover and an EU subsidiary or branch generating more than €200 million in turnover may be required to comply with CSRD reporting requirements.

Why This Matters for TAP’s Sustainability for Investment Professionals Course

TAP’s Sustainability for Investment Professionals course helps CPAs, financial advisors, and investment professionals understand why sustainability reporting is not just a compliance topic. It affects financial analysis, due diligence, reporting controls, operating risk, investor expectations, and business valuation.

For U.S. professionals, CSRD is an example of how sustainability information can become financially relevant even when the company is not headquartered in Europe. A U.S. company may need to report directly, support an EU subsidiary’s reporting, respond to customer requests, or provide information for financing and investment review. Understanding these requirements helps financial professionals ask better questions and identify reporting risk before it becomes a business problem.