Navigating ESG in ITAD: CSRD Updates & Carbon Readiness

Updated: 12th May 2026

As global organizations accelerate their sustainability agendas, environmental, social, and governance (ESG) considerations have moved firmly from the margins to the boardroom. For enterprises managing large volumes of IT and data center assets, sustainability reporting is no longer just a compliance exercise, it is a strategic capability.

In Europe, the Corporate Sustainability Reporting Directive (CSRD) remains a cornerstone of this shift. In March 2026, the EU adopted the CSRD “Omnibus I” amendments, significantly narrowing scope and simplifying reporting requirements while preserving the directive’s core objective: credible, comparable, useful sustainability disclosures.

For companies involved in IT Asset Disposition (ITAD) and data center decommissioning, these changes sharpen the focus on high‑quality, auditable data, particularly around circularity outcomes and carbon impacts. This article explains what has changed under CSRD Omnibus I, what remains the same, and how robust ITAD reporting, supported by tools such as SK tes’ Carbon Loop reporting, helps organizations turn ESG compliance into measurable value.

Let’s look at how some of these regulations will affect your business.  

1. CSRD Omnibus I: What Changed in 2026

2. What Hasn’t Changed: Why ESG Data Still Matters

3. CSRD, ESRS, and Carbon Reporting: Why ITAD Data Is Critical

4. Carbon Loop Reporting: Turning ITAD Outcomes into ESG‑Ready Data

5. CSDDD and Due Diligence: A Related but Distinct Obligation

6. Turning Simplification into Advantage

CSRD Omnibus I: What Changed in 2026

The CSRD Omnibus I amendments, adopted as Directive (EU) 2026/470 and entering into force in March 2026, recalibrate the EU’s sustainability reporting framework to reduce administrative burden while maintaining transparency.

A narrower scope, focused on the largest companies

Under the amended CSRD, mandatory sustainability reporting is now primarily targeted at the largest undertakings, generally those exceeding 1,000 employees and €450 million in net turnover, with specific rules for corporate groups and non‑EU parent companies operating in the EU.

As a result, many organizations that were previously preparing for CSRD reporting are now outside direct legal scope. However, this does not mean ESG reporting expectations disappear.

Updated reporting timelines

For companies that remain in scope:

• EU undertakings will report from 2028, using data from financial years starting on or after 1 January 2027.

• Non‑EU parent companies remain on track to report from 2029, using FYs starting on or after 1 January 2028.

• Reporting datapoints have been significantly reduced, with greater emphasis on material, decision‑useful information.

• Sector‑specific ESRS standards have been removed, although non‑binding guidance may follow.

• The planned transition from limited assurance to reasonable assurance has been dropped. Sustainability reports will continue to be subject to limited assurance only.

Earlier ‘wave two and three’ timelines have been postponed under the EU’s ‘stop‑the‑clock’ mechanism.

Simplified ESRS requirements

Alongside scope changes, the European Sustainability Reporting Standards (ESRS) have been streamlined:

Value‑chain protections for smaller companies

Omnibus I also introduces explicit protections for companies with fewer than 1,000 employees that sit within the value chains of reporting entities. These organisations may decline sustainability information requests that exceed the boundaries of a forthcoming voluntary EU reporting standard, based on the VSME framework.

In practice, this is intended to reduce excessive ESG questionnaires and it also increases the value of standardized, reusable datasets that can be shared efficiently with customers and partners.

What Hasn’t Changed: Why ESG Data Still Matters

While Omnibus I reduces the number of companies directly subject to CSRD, it does not weaken the strategic importance of sustainability reporting.

For companies that remain in scope, CSRD still demands:

• Structured disclosures aligned with ESRS
• Robust governance and internal controls
• Traceable, auditable data that stands up to external assurance
• Customer and procurement requirements
• Investor and lender expectations
• Global alignment with ISSB, GHG Protocol, and other frameworks

For companies outside formal scope, ESG reporting continues to be driven by:

In other words, sustainability reporting has become a market expectation, not just a regulatory one.

To access more information about this, download the Sustainability report.

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CSRD, ESRS, and Carbon Reporting: Why ITAD Data Is Critical

Under ESRS E1 (Climate Change) and ESRS E5 (Resource Use and Circular Economy), organisations must disclose how they manage emissions, resource efficiency, and end‑of‑life impacts across their value chains.

For IT‑intensive businesses, this places ITAD squarely in the reporting spotlight.

High‑quality ITAD data supports:

• Scope 3 emissions accounting, particularly avoided emissions from reuse and refurbishment
• Avoided emissions reporting (Scope 4), from reuse, refurbishment and recycling outcomes
• Circularity metrics, including reuse rates, recycling yields, and material recovery
• Audit‑ready evidence for assurance and stakeholder scrutiny

This is where SK tes’ Carbon Loop reporting plays a central role.

Carbon Loop Reporting: Turning ITAD Outcomes into ESG‑Ready Data

SK tes Carbon Loop reporting is designed to help organisations translate ITAD activities into credible, standardized ESG evidence that supports CSRD, ESRS, and global sustainability reporting.

Carbon Loop reporting provides:

• Quantified avoided emissions from reuse, resale, and responsible recycling
• Clear linkage between ITAD outcomes and Scope 3 emissions categories
• Consistent, auditable data aligned with recognized carbon accounting methodologies
• Reporting outputs that are usable across CSRD, ISSB, CDP, EcoVadis, and voluntary disclosures

As CSRD reporting becomes more focused on material, high‑quality datapoints, tools like Carbon Loop help organisations reduce reporting friction while increasing confidence in their disclosures.

CSDDD and Due Diligence: A Related but Distinct Obligation

The Omnibus I package also amended the Corporate Sustainability Due Diligence Directive (CSDDD), significantly narrowing its scope and removing certain requirements that were originally proposed, including specific climate transition plan obligations.

While CSRD and CSDDD now have clearer boundaries, due diligence expectations remain relevant, particularly in sectors like electronics, where responsible downstream processing, labour practices, and environmental compliance are under scrutiny.

For ITAD and e‑waste recycling, transparent reporting and third‑party verified data remain key differentiators when customers assess supplier risk and resilience.

Turning Simplification into Advantage

The CSRD Omnibus amendments are not a retreat from sustainability reporting, they are a reset toward proportionality and quality.

Organizations that succeed under the revised framework will be those that:

• Focus on material impacts, not volume of disclosure
• Build repeatable, auditable data pipelines
• Work with partners who can provide credible ESG evidence by design
• Explore Carbon Loop Reporting
• Speak to our ESG and ITAD specialists

By embedding Carbon Loop reporting into ITAD programs, SK tes helps clients move beyond compliance, supporting circular economy strategies, carbon reduction goals, and confident engagement with regulators, investors, and customers.

Take the Next Step

Want to understand how your ITAD program generates CSRD‑ready carbon and circularity reporting?

With CSRD requirements clarified and reporting expectations rising across global value chains, now is the time to ensure your IT asset disposition (ITAD) strategy delivers proof, not just promises.