EU DIGITAL SUSTAINABILITY RULES: WHAT US WEBSITES NEED TO KNOW
The European Union's Corporate Sustainability Reporting Directive (CSRD) is now in force. It affects companies outside the EU too — including US companies that sell to or operate in Europe. Here's what it means for your website and your digital emissions reporting.
Start Measuring Your Digital Emissions →Note: This guide is for informational purposes only and does not constitute legal or compliance advice. Consult qualified legal counsel for advice specific to your organization's situation.
What is the CSRD?
The Corporate Sustainability Reporting Directive (CSRD) is an EU regulation that requires companies to report on their environmental, social, and governance (ESG) performance. It replaced the earlier Non-Financial Reporting Directive (NFRD) and significantly expands both the scope of who must report and the detail of what must be reported.
Under the CSRD, companies must report against the European Sustainability Reporting Standards (ESRS), which cover a range of ESG topics including climate change (ESRS E1), pollution, biodiversity, workers' rights, and governance. ESRS E1 specifically covers greenhouse gas emissions — including Scope 3 indirect emissions, which is where digital infrastructure sits.
Does the CSRD Apply to US Companies?
Yes — in several scenarios. The CSRD applies to non-EU companies that meet certain thresholds related to EU activity. Specifically, a non-EU parent company must comply if it has:
Net EU turnover > €150 million
If your company generates more than €150 million in annual revenue from the EU, the CSRD's third-country provisions may apply to your EU subsidiary or branch.
EU subsidiary above size thresholds
If you have an EU subsidiary that is a 'large undertaking' (more than 250 employees, OR >€50M revenue, OR >€25M balance sheet), that subsidiary may be required to report under CSRD.
EU-listed securities
Companies whose securities are listed on EU-regulated markets are in scope regardless of headquarters location.
Even if you're not directly in scope today, your enterprise customers who are in scope will require sustainability data from suppliers. If your product or service is part of their Scope 3 supply chain, they will ask you for documented emissions data.
Where Does Website Carbon Fit?
Under the GHG Protocol (which the ESRS references), emissions are categorized as Scope 1 (direct), Scope 2 (purchased energy), and Scope 3 (indirect value chain emissions). Website operations fall into Scope 3, most commonly:
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Category 1 — Purchased goods and services
Cloud hosting, CDN, and DNS services your website depends on.
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Category 11 — Use of sold products / delivered services
Emissions generated when users interact with your website or digital service.
Website carbon data (grams of CO₂ per page view × page views) gives you a quantifiable, methodology-backed figure for this Scope 3 category.
The CSRD Reporting Timeline
2024 (reports filed in 2025)
Large EU public interest entities (>500 employees) already in scope.
2025 (reports filed in 2026)
Other large EU companies (>250 employees OR >€50M revenue OR >€25M balance sheet).
2026 (reports filed in 2027)
Listed SMEs (small and medium enterprises) on EU-regulated markets.
2028 (reports filed in 2029)
Third-country (non-EU) companies with >€150M EU net turnover and an EU subsidiary or branch.
How to Get Ahead of Compliance Now
The best time to start building a digital emissions baseline was a year ago. The second best time is today. CSRD reporting requires documented, time-series data — a one-off scan taken the week before an audit is not sufficient. Here's what to do now:
Start measuring immediately
Add your key URLs to a carbon monitoring tool and begin collecting daily scan data. Every day you wait is a day of baseline you won't have.
Build a methodology document
Record what tool you're using, what model it applies (SWD), which URLs are being tracked, and why those represent your material digital footprint.
Calculate total monthly emissions
Use CO₂-per-page-view × monthly page views for each URL to produce a total monthly digital carbon figure.
Include in your Scope 3 inventory
Add website emissions to your GHG inventory under the appropriate category. Flag it as an estimated figure using a recognized methodology (SWD model).
Track improvement
Set a target (e.g., reduce average CO₂-per-page-view by 20% in 12 months) and track progress against it. Demonstrable improvement is more valuable than a perfect starting score.
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