Your group must file CSRD sustainability reports in the EU — and your Vietnamese plant’s ESG data is a mandatory part of that consolidated report. Vietnamese subsidiaries are not “outside” the CSRD.
What the CSRD is and its phase-in
Directive (EU) 2022/2464 — the Corporate Sustainability Reporting Directive, effective 5 January 2023 — requires large EU companies to publish sustainability reports under ESRS (European Sustainability Reporting Standards), covering environment, social and governance, with mandatory assurance (limited assurance first, moving to reasonable).
Phase-in runs from financial year 2024 (ex-NFRD large companies first, then expanding). Note: the Omnibus package (02/2025) proposes delaying the timeline and narrowing scope — but at the time of writing it remains a proposal; groups should not stop preparing.
Why Vietnamese subsidiaries get named
The CSRD requires consolidated reporting — covering the entire value chain: the group’s own operations, subsidiaries and upstream/downstream links. Vietnamese subsidiaries (plants, R&D centres, trading companies) must supply ESG data for the consolidated report:
- E (environment): GHG emissions (Scope 1, 2 and relevant Scope 3), energy, water, waste.
- S (social): workforce composition, accidents, training, gender equality, human rights in the chain.
- G (governance): anti-corruption, whistleblower protection, governance structure.
No data from Vietnam = incomplete consolidated report = a qualified assurance opinion.
Which data, which standards
ESRS does not accept “estimates for show”:
- Emissions: measured/inventoried GHG figures under recognised methods (GHG Protocol) — Vietnamese plants need a proper emissions inventory, not “electricity-bill guessing”.
- Labour: granular HR data (gender, contract types, turnover, accidents) — HR systems must export reports, not hand-counted Excel.
- Supply chain: ESG information on the Vietnamese subsidiary’s suppliers (assessments, audits) — the value chain includes the subsidiary’s downstream too.
- Double materiality: subsidiaries join the two-way impact assessment (company impacts on environment/society, and vice versa).
Assurance: Vietnamese data gets scrutinised too
CSRD sustainability reports need independent assurance — and assurers do not just sit in Brussels: they test source data at subsidiaries, including in Vietnam. Emission figures without inventory methodology, labour figures not matching books — the assurer qualifies the opinion, and a qualification in a sustainability report is as serious as in financial statements.
In practice, groups should dry-run ESG data collection + assurance at the Vietnamese subsidiary one year before the official reporting year.
Preparation timeline for the Vietnamese subsidiary
- 2026: first GHG inventory; HR-system review — can it export granular labour data; supplier list plus preliminary ESG screening.
- One year before reporting: full dry run — ESRS data collection, internal assurance, gap remediation.
- Reporting year: deliver data to the group on time; cooperate with the independent assurer.
- Throughout: appoint a Vietnam ESG contact (strong English, ESRS-literate) — without one, data never arrives on time.
Do not confuse the CSRD with other laws
The CSRD is about reporting (transparency), unlike the CSDDD (diligence + civil liability) and the EU Taxonomy (classifying sustainable activities). But all three use the same underlying ESG dataset — build the data system once, use it for all three. A Vietnamese subsidiary preparing solid ESG data today simultaneously serves the group’s CSRD, CSDDD and Taxonomy — one effort, triple duty.
Frequently asked questions
What is the CSRD?
The EU Corporate Sustainability Reporting Directive (2022/2464, effective 5/1/2023): large EU companies publish ESRS sustainability reports with mandatory assurance; phasing in from FY2024.
Must Vietnamese subsidiaries file CSRD reports?
Not directly, but they must supply ESG data (environmental, social, governance) for the group’s consolidated report — the CSRD requires consolidated, value-chain-wide reporting.
Which ESG data must a Vietnamese subsidiary prepare?
GHG inventories (GHG Protocol), granular labour data, supplier ESG information, and participation in double-materiality assessment.
Will Omnibus delay the CSRD?
Omnibus (proposal 02/2025) proposes timeline delays and narrower scope, but at the time of writing it is still a proposal, not law — do not stop preparing.
Contact FLAT Law Firm
FLAT Law Firm advises Vietnamese subsidiaries on CSRD ESG-data readiness: emissions inventories, labour-data systems and assurance dry runs. Contact us in 2026.
