Between 2023 and 2024, large European companies recruited Chief Sustainability Officers in anticipation of a reporting requirement that was set to expand rapidly to tens of thousands of companies. Since then, the European legislator has postponed two waves of application and opened a revision of the scope itself.

The result is a situation that few organizations have been able to interpret: sustainability teams formed for an obligation whose timeline and scale have changed along the way. The question of recruitment is no longer framed in the same terms as it was two years ago.

Key Figures to Know

Why This Topic Is Pressing Now

In February 2025, the European Commission presented a simplification package targeting several sustainability texts, including the CSRD and corporate sustainability due diligence. This package split into two.

The first part, adopted quickly, postpones the entry into force for Wave 2 and 3 companies by two years. It freezes an obligation for which many organizations had already committed resources.

The second part focuses on the content itself: raising the employee threshold, reducing the number of required data points, scrapping sector-specific standards, and regulating what a large company can demand from its suppliers.

For executive management, the message is blunt. The obligation is not disappearing; it is narrowing to a tighter scope and shifting in time. The human capital investments made in 2023 and 2024 find themselves partially ahead of schedule, sometimes on a scope that will never be reached.

What the CSRD Really Demands

Three mechanisms structure the obligation, and these are what determine the skills that need to be recruited.

Double Materiality. The company must analyze its sustainability issues from two simultaneous perspectives: the impact of its activities on the environment and society, and the effect of sustainability issues on its own financial performance. This analysis conditions all subsequent reporting. It is as much a matter of management control and strategy as it is of the environmental function.

ESRS Standards. Reporting follows a standardized framework, with defined data points, an imposed structure, and integration into the management report. It is not a free-form sustainable development report; it is a normative exercise comparable in its logic to a financial consolidation.

External Assurance. The published information is verified by an independent third party, at a limited assurance level. A non-traceable data point will not pass.

These three mechanisms explain why successful hires in this field are not environmental expertise hires. They are hires of individuals capable of producing auditable data within a regulated framework.

The Application Schedule After the Postponement

The first wave remains subject to the obligation and is already publishing. It is the companies in waves 2 and 3 that benefit from the delay, and among them, a portion will fall out of scope if the threshold increase is confirmed.

What the Scope Change Means for Recruitment

Four effects are happening simultaneously, and they are pulling in opposite directions.

Wave 1 companies are tightening their requirements. They have published their first exercise; they know its weaknesses. They are no longer recruiting someone to launch a process; they are recruiting someone capable of securing the reliability of data in front of an assurance provider.

Wave 2 companies are slowing down. A two-year delay is enough to deprioritize a hire. Some are freezing open positions; others are downgrading them.

Companies falling out of scope are making trade-offs. An organization of 400 employees preparing for the CSRD will not recruit a Chief Sustainability Officer if it is no longer required to do so. It will keep the subject on its radar, driven by demand from its major clients and financiers, but it will not fund an executive committee position for it.

The talent market is becoming unbalanced. Individuals trained and experienced in standardized reporting remain rare, while demand is concentrating on a smaller number of companies with higher requirements. For Wave 1 organizations, the tension over these profiles is not decreasing; it is increasing.

The Four Functions that Structure a CSRD Organization

Sustainability Leadership. Strategic ownership, double materiality arbitration, dialogue with the board of directors and investors. An executive committee position in Wave 1 organizations, often reporting to the CEO or the CFO.

Non-Financial Reporting Management. Production, collection, traceability, and control of ESRS data. This is a management control function applied to non-financial data, not an environmental function. The natural profile comes from management control, audit, or consolidation.

Sustainability Data. Information systems, consolidation scopes, quality, and auditability. An underestimated function, and it is often where a first exercise fails.

Legal Compliance. Coordination with corporate sustainability due diligence, taxonomy, and sector-specific obligations. Frequently reporting to the legal department rather than to sustainability.

An organization that hires a single person to cover these four dimensions is setting itself up for difficulty. They fall under distinct skill sets and different career paths.

Where Companies Go Wrong in These Recrutiments

Hiring conviction rather than competence. Personal commitment to environmental issues does not predict the ability to produce an auditable report. The two can meet, but they should not be confused.

Reporting to the wrong department. A sustainability department reporting to communications will never obtain data from operational departments. Reporting lines determine real authority.

Confusing strategy with production. The profile that builds a decarbonization pathway is not the one that maintains a non-financial closing schedule. Asking for both from the same person leads to failure on both fronts.

Underestimating the data function. The quality of information depends on the systems that collect it. An organization that recruits a sustainability director without strengthening its collection capacity will publish numbers it cannot justify.

Freezing recruitments on the basis of the postponement. The two-year delay concerns publication, not preparation. A Wave 2 organization that waits until 2027 to start will have to produce an exercise without data history.

How to Assess a Sustainability Profile Before Appointing

Five points establish the actual solidness of a candidate.

1. Have they already produced reporting subject to external assurance? The difference between a voluntary report and an audited exercise is the only experience that counts.

2. Can they defend a materiality choice? Ask them to explain an actual trade-off, including what was included, what was excluded, and why.

3. Do they know the data production pipeline? Someone who does not know where a figure comes from will not be able to get it certified.

4. Have they confronted a reluctant operational department? The function is exercised cross-functionally without hierarchical authority. It is an exercise in influence.

5. What is their relationship to shifting regulatory constraints? The framework is moving. A profile that experiences every revision as a personal setback will burn out.

Frequently Asked Questions

Has the CSRD been scrapped or postponed? Neither in its entirety. The directive remains in force, and the first wave of companies is already publishing. A text adopted in April 2025 postponed the entry into force for waves 2 and 3 by two years. A review of the scope and content has been launched in parallel, with a proposed threshold increase to 1,000 employees.

Should you still recruit a sustainability director in 2026? For a first-wave company, yes, and requirements have tightened after a first published exercise. For a company that would fall out of the revised scope, the question becomes a commercial trade-off rather than a regulatory one: demand then comes from major clients and financiers.

What reporting line should a sustainability department have? Executive management or finance in organizations where reporting is the main issue. Reporting to communications deprives the function of the authority necessary to obtain data from operational departments.

What is the difference between a CSR profile and a non-financial reporting profile? The first carries a strategy and commitments, while the second produces traceable and auditable data within a standardized framework. Career paths differ: the second frequently comes from management control, audit, or consolidation.

Does the two-year postponement justify freezing recruitments? The postponement concerns publication, not preparation. A first exercise requires historical data and proven collection processes. An organization that starts in the year of its first publication will produce a fragile report.

What is double materiality? The obligation to analyze sustainability issues from two simultaneous angles: the company's impact on the environment and society, and the effect of these issues on its financial performance. This is the starting point for all reporting, and the most structuring decision.

Key Takeaways

The CSRD remains in force. The first wave is publishing. Waves 2 and 3 have a two-year extension.

The scope is narrowing. A portion of the companies that were preparing will likely fall out of the obligation.

Successful hires are not environmental expertise hires. They are hires of individuals capable of producing auditable data within a regulated framework.

Four distinct functions structure a CSRD organization. Entrusting them to a single person leads to failure.

The postponement concerns publication, not preparation. Freezing recruitment for two years means producing a first exercise without history.

Laroze Partners' Perspective

The question asked of executive management is no longer "should we recruit an ESG profile." It has become "what is the actual nature of the obligation that concerns us, and when."

The answer determines everything else: the level of the position, its reporting line, the type of background to target. A Wave 1 organization that has already published is looking for reliability assurance. An organization that will fall out of scope is looking for something else, and probably not an executive committee position.

This preliminary clarification avoids the most expensive recruitment there is: one that responds to an poorly identified obligation.