Corporate reporting

Directive (EU) 2022/2464 · ESRS · Stop-the-clock · Omnibus I

Where the entity falls within the applicable CSRD scope in force, disclosure in the sustainability statement subjects waste management to the assurance auditor’s scrutiny. EoL360 provides the documentary material that backs the statement’s claims.

Scope after Omnibus I

Directive (EU) 2025/794 (Stop-the-clock) and Directive (EU) 2026/470 (Omnibus I) have recalibrated the scope of application. The direct scope in force requires more than 1,000 employees and more than €450 million in net turnover.

The value of this plane does not disappear when the entity falls outside the direct scope. Many companies that left the mandatory scope after the 2025 and 2026 reforms still face indirect pressure from their large clients through value-chain questionnaires, supplier codes of conduct and ESG information requests.

Value-chain effect

Even where a company falls outside the direct scope, its in-scope clients will keep requesting sustainability information so they can report their own consistently. The ability to answer those questionnaires with documentary evidence becomes a factor of commercial continuity.

Applicable framework

Directive (EU) 2022/2464

CSRD. General framework for corporate sustainability reporting and assurance by an independent auditor.

Delegated Regulation (EU) 2023/2772

ESRS. European sustainability reporting standards. Particularly relevant to IT end of life: ESRS E5 (resource use and circular economy) and ESRS G1 (business conduct).

Directive (EU) 2025/794

Stop-the-clock. Deferral of application to certain waves. Initial recalibration of the scope.

Directive (EU) 2026/470

Omnibus I. Direct scope in force: more than 1,000 employees and more than €450M in net turnover. It narrows the direct scope but amplifies indirect pressure on the value chain.

Implications of an unsupported statement

Where the entity falls within the applicable CSRD scope, declaring a reuse-preparation rate of zero in the IT flow can increase the risk of:

Environmental sanctioning procedure

Opening of a procedure by the regional authority on detecting the inconsistency between the reported figure and the hierarchy of art. 8, Law 7/2022.

Auditor observations

Assurance of the sustainability information may issue qualifications where the claim is not supported by robust asset-level documentary evidence.

Sustainable finance

Indirect effects on taxonomy, green facilities, sustainability-linked bond conditions and ESG clauses in financing contracts.

Public procurement

Impact on award criteria in contracts where circularity, ESG or responsible business-conduct indicators are valued.

How EoL360 covers it

ESRS E5 · Resources and circularity

Documentary material backing the statement’s claims on reuse rate, routing to recycling and flow traceability. Every aggregated figure is backed by an individualised, asset-by-asset case file.

ESRS G1 · Business conduct

Support for disclosures on supplier-management practices, supply-chain integrity and responsible conduct in end-of-life operations.

Defence before the auditor

Ability to present robust, traceable documentary evidence to the assurance provider. Reduces the risk of qualifications for unsupported information.

Value-chain questionnaires

Reusable material to answer clients’ ESG questionnaires and supplier codes of conduct. Turns internal compliance into a commercial argument before in-scope clients.

From statement claim to traceable evidence

We show you how to connect sustainability reporting with real, asset-by-asset operations.

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