Business Continuity ESG Blog

The EU's CSRD Rules Are Coming — Will They Impact U.S. Real Estate?

Written by William Tygart | 6/19/25 7:17 PM

If you’ve never heard of the Corporate Sustainability Reporting Directive (CSRD), that’s about to change. The EU’s sweeping ESG disclosure regulation is already reshaping how global companies report their environmental and social impacts — and U.S. commercial property firms may be more exposed than they think.

In 2025, it's not just about where your company operates — it's about who you do business with. And if any of those entities are in the EU, the CSRD might already apply to you.

What Is CSRD, and Why Does It Matter?

The CSRD is the European Union’s new standard for corporate sustainability reporting. It expands on the previous Non-Financial Reporting Directive (NFRD), dramatically increasing:

  • Who must report (many more companies, including non-EU firms)

  • What must be reported (detailed ESG data, risk exposure, and governance)

  • How it’s reported (using standardized, auditable digital formats)

The goal? To make ESG performance as transparent — and comparable — as financial performance.

Wait… We’re in the U.S. — Does This Apply to Us?

Surprisingly, yes.

If your company is:

  • A subsidiary of an EU-based parent company

  • A supplier to a company reporting under CSRD

  • An investee or portfolio holding of an EU financial institution

  • A partner in a joint venture with EU exposure

…you may be required to submit sustainability data — even if you’re based entirely in the U.S.

CSRD’s reach is global — and it comes with legal weight.

Why This Affects Commercial Property Owners

Many real estate firms and asset managers fall into the net via:

  • Cross-border capital partnerships

  • European-based REITs or funds

  • Large tenants with EU ESG obligations

  • Global supply chains for building materials

In each case, your ESG performance data may be requested, audited, or factored into another company’s disclosures — even if you’re not filing directly.

What CSRD Requires (And Why It’s Tough)

CSRD demands that firms report:

  • Scope 1, 2, and 3 emissions (yes, including embodied carbon and tenant energy use)

  • Climate risk exposure (physical and transitional)

  • Social and workforce metrics (DEI, health, equity)

  • Governance and policy frameworks

All of this must be:

  • Digitally tagged using European Sustainability Reporting Standards (ESRS)

  • Auditable by third-party assurance providers

  • Filed in a format compatible with EU regulators

How to Prepare Without Panicking

  1. Map Your Exposure
    Identify EU-linked partners, clients, or investors in your ecosystem.

  2. Centralize ESG Data Now
    Even if you don’t need to file this year, start collecting Scope 1–3 data and resilience metrics.

  3. Align with CSRD-Ready Frameworks
    Tools like GRI, TCFD, and SASB will help bridge the gap.

  4. Signal Your Readiness
    If you’re ahead of the curve, make it known — buyers and partners are looking for low-friction compliance.

Related Reading from BCESG.org

  • [ESG: U.S. Political and Regulatory Landscape]

For decades, U.S. firms could treat ESG disclosures as optional or cosmetic.

With CSRD, that era is over — even if you never cross an ocean.

The firms that thrive in this new landscape will be the ones who treat ESG like accounting: detailed, auditable, and part of the business infrastructure.