Since 2024, the Corporate Sustainability Reporting Directive (CSRD) has required large companies to report annually on their sustainability impact. From 2026 this is being extended to medium-sized companies. Corporate gifts, corporate clothing and merchandise fall under Scope 3.1 (purchased goods). On this page we explain which documentation you need, which ESRS standards are relevant and how we support your compliance team.

CSRD in a nutshell

The CSRD (Corporate Sustainability Reporting Directive) is the European legislation that makes sustainability reporting mandatory. It replaces the older NFRD and considerably widens the scope. Companies report in line with the ESRS (European Sustainability Reporting Standards) and must have their reporting audited by an external party, with limited assurance from 2024 and reasonable assurance later.

Who the CSRD applies to

Financial year 2024: large public-interest entities (more than 500 employees, 2025 annual report).
Financial year 2025: large companies (at least 2 of: 250+ employees, EUR 40 million turnover, EUR 20 million balance sheet total).
Financial year 2026: listed SMEs (2027 annual report).
Financial year 2028: non-EU companies with significant EU activity.

Even companies that do not fall directly under the CSRD are affected: large clients ask for your sustainability data to map their own Scope 3.

ESRS standards that affect your corporate gifts

ESRS E1 Climate Change: Scope 1, 2 and 3 emissions, including purchased goods. Corporate gifts fall under Scope 3.1.
ESRS E2 Pollution: use of chemicals in production, relevant for textiles.
ESRS E3 Water and Marine Resources: the water footprint of cotton growing and dyeing.
ESRS E5 Resource Use and Circular Economy: recycled content, reuse, end of life.
ESRS S2 Workers in the Value Chain: working conditions at suppliers, critical for textiles.
ESRS G1 Business Conduct: supplier policy and ethical purchasing.

Double materiality assessment

The CSRD works with double materiality: you report on topics that are financially material AND on topics where your company has a material impact on people and the environment. For most companies, corporate gifts are financially too small to be material on their own, but they do belong in the impact assessment (value chain impact on labour and climate).

The documents we supply

GOTS, GRS, FSC and OEKO-TEX transaction certificates per order.
A CO2 estimate per product line based on LCA data.
Declarations of origin (Portuguese production, EU production).
Fair Wear Foundation membership declaration per supplier.
Packaging and end-of-life information (recyclability, material passport).

EU Green Claims Directive

Alongside the CSRD comes the Green Claims Directive, which bans vague green claims without scientific substantiation. Terms such as “eco-friendly”, “green” or “natural” without certification will be prohibited. For your reporting this means basing sustainability communication on certificates or published data. On our avoiding greenwashing page you will find concrete examples.

A practical approach for your team

Take stock: which categories of corporate gifts and corporate clothing do you buy each year? Group them by category.
Material choice: within each category, choose the most certified option (see our materials guide).
Request certificates: the transaction certificate with every order.
Calculate CO2: archive an LCA estimate per product line.
Document your policy: agree internal purchasing rules and add them to your sustainability report.
Report: include it under ESRS E1 (climate), E5 (circularity) and S2 (labour).

Frequently asked questions about the CSRD and corporate gifts

Do we need to report corporate gifts separately?

Not as a separate line, but as part of Scope 3.1 (Purchased Goods and Services) and indirectly through ESRS S2 (workers in the value chain).

What is the difference between the CSRD and the NFRD?

The NFRD (Non-Financial Reporting Directive) was its predecessor. The CSRD is stricter: more companies fall under it, reporting follows binding ESRS standards, and external assurance and digital tagging (ESEF) are mandatory.

What if a supplier cannot provide certificates?

Then you record it as a ‘gap’ in your reporting and work on an improvement plan. We help you switch to certified alternatives within the same budget.

Do corporate gifts count towards Scope 3 category 11 (use of sold products)?

No. Category 11 covers products you sell to customers that consume energy during use. Corporate gifts fall under category 1 (purchased goods and services).

Strengthening your compliance together

We support purchasing, HR and compliance teams in building a CSRD-proof policy for gifts and workwear. From certified materials to documentation: everything ready for your external audit. Contact our team for tailored CSRD advice.