CSRD A1-40a: Sustainability report at the level of a third-country group by EU subsidiaries and branches

What does A1-40a require?

An EU subsidiary with prior-year net turnover above EUR 200 million, or (where there is no such subsidiary) an EU branch with turnover above EUR 200 million, of a non-EU group with EU turnover above EUR 450 million in each of the last two years must publish a group-level sustainability report covering the transition plan, targets, governance, policies, incentives, due diligence, impacts and, where appropriate, indicators, under the third-country standards or the ESRS or an equivalent. If the parent withholds information it must request it, publish what it has and state that the parent did not provide the rest; the report carries an assurance opinion or a statement that none was provided. Financial holding groups with independent subsidiaries may be excused. Applies for financial years from 1 January 2028. As amended by Directive (EU) 2026/470.