CSRD & Advertising: Your 2026 Compliance Roadmap

The Corporate Sustainability Reporting Directive (CSRD) is no longer a future concern. It’s here. And if you’re in advertising or marketing, it affects you directly.

Here’s the situation in 2026: companies across Europe are filing their first CSRD reports. Early movers discovered the hardest part isn’t the regulation itself—it’s measuring Scope 3 emissions from digital advertising. This guide shows you how to get it right.

What Changed in December 2025

The CSRD Omnibus I package, approved by the European Commission in December 2025, brought important simplifications:

What stayed the same:

Scope 3 disclosure requirements (including advertising)
Mandatory external audit
ESRS E1 climate reporting standards
Penalty framework (up to 5% of global revenue)

What changed:

Simplified reporting templates for first-time filers
Phased approach for Scope 3 categories (advertising included in Phase 1)
Clearer materiality assessment guidelines
Streamlined data quality requirements

Bottom line: Compliance is easier than it was in 2024, but it’s still mandatory. And digital advertising falls squarely within Scope 3, Category 1: Purchased Goods and Services.

Who Must Comply in 2026

If your company meets these criteria, CSRD applies to you:

EU Companies (2 of 3 criteria):

250+ employees
€50M+ annual revenue
€25M+ total assets

Non-EU Companies:

€150M+ EU revenue for 2 consecutive years
At least one EU subsidiary or branch above thresholds

Reporting schedule:

Already under NFRD: Reporting FY 2024 data (filing now in 2026)
Large EU companies: Reporting FY 2025 data (filing early 2027)
Listed SMEs: Reporting FY 2026 data (filing 2027)

If you’re a large EU company, you’re preparing your first CSRD report right now for FY 2025. That report is due early 2027.

Why Advertising Teams Need to Care

Every euro spent on digital advertising generates CO₂ emissions. Under CSRD, these emissions must be:

Calculated using standardized methodology
Reported in your annual sustainability statement
Verified by an external auditor
Reduced over time according to science-based targets

This isn’t optional. It’s not coming. It’s happening now.

What You Must Report: ESRS E1 Requirements

ESRS E1 (Climate Change) requires specific disclosures about your advertising emissions:

1. Gross Scope 3 Emissions (ESRS E1-6)

Total greenhouse gas emissions from digital advertising activities, measured in tonnes CO₂ equivalent (tCO₂e).

Example format:

Scope 3, Category 1 - Digital Advertising
FY 2025: 847 tCO₂e
FY 2024: 1,243 tCO₂e
Change: -32%

2. Emissions Breakdown (ESRS E1-6)

Detailed breakdown showing:

Platform (Google Ads, Meta, DV360, The Trade Desk, etc.)
Format (display, video, native, audio, etc.)
Geography (country or region)
Campaign type (awareness, consideration, conversion)

3. Methodology Disclosure (ESRS E1-7)

How you calculated emissions:

Calculation methodology (must align with GHG Protocol)
Data sources and quality assessment
Assumptions and limitations
Changes from prior year

Critical: Use GMSF v1.2 methodology. It’s now the industry standard and aligns with CSRD requirements. Spend-based calculations overstate emissions by 450% and won’t pass audit.

4. Reduction Targets (ESRS E1-4)

Science-based targets for reducing advertising emissions:

Long-term goal (typically 2030 or 2050)
Interim milestones (2026, 2027, 2028, etc.)
Progress tracking
Alignment with 1.5°C pathway

5. Action Plans (ESRS E1-3)

Specific initiatives to achieve reductions:

Creative optimization programs
Supply path optimization
Carbon-aware buying strategies
Budget allocated
Teams responsible

How to Calculate Advertising Emissions

This is where most companies struggle. Here’s the right approach:

Use GMSF v1.2

The Global Media Sustainability Framework v1.2 (released late 2025) is now fully operational. It provides:

Standardized calculation methodology
Activity-based measurement (not spend-based)
Alignment with GHG Protocol and ISO 14064
Audit-ready documentation

The Four-Step Process

Step 1: Data Collection

Gather campaign data from all platforms:

Impressions, clicks, conversions
Creative specifications (file size, format, duration)
Geographic distribution
Device breakdown
Supply chain participants

Step 2: Energy Calculation

Calculate energy consumed at each stage:

Total Energy =
  Data Center Energy +
  Network Transfer Energy +
  Device Rendering Energy +
  Third-Party Tracking Energy

Step 3: Emissions Calculation

Apply regional carbon intensity factors:

CO₂ Emissions = Energy (kWh) × Carbon Intensity (g CO₂/kWh)

Step 4: Aggregation & Reporting

Aggregate by required categories and generate ESRS E1 compliant reports.

Example: CSRD-Compliant Report

Company: European Retailer Ltd. Period: FY 2025 Scope 3, Category 1: Digital Advertising

Total Emissions: 1,124 tonnes CO₂e

Platform Breakdown:

Google Ads: 438 tCO₂e (39%)
Meta: 337 tCO₂e (30%)
DV360: 225 tCO₂e (20%)
Other: 124 tCO₂e (11%)

Format Breakdown:

Display: 450 tCO₂e (40%)
Video: 393 tCO₂e (35%)
Native: 169 tCO₂e (15%)
Search: 112 tCO₂e (10%)

YoY Change: -36% (vs. FY 2024: 1,756 tCO₂e)

Methodology: GMSF v1.2, aligned with GHG Protocol and ISO 14064-1

Data Quality: 94% measured data, 6% estimated using GMSF industry averages

Reduction Initiatives:

Creative compression program (avg. file size reduced 45%)
Supply path optimization (limited to 4 preferred SSPs)
Carbon-aware bidding implementation
MFA domain blocking (12,000+ domains)

Common Compliance Mistakes

Mistake 1: Using Spend-Based Calculations

Wrong: “We spent €5M on ads, so emissions = €5M × 0.2 kg CO₂/€ = 1,000 tonnes”

Right: Activity-based calculation using actual impressions, file sizes, and energy consumption.

Why it matters: Spend-based calculations overstate emissions by 450%. Your auditor will reject this.

Mistake 2: Incomplete Platform Coverage

Wrong: Reporting only Google Ads and Meta.

Right: All digital advertising platforms where you spent money.

Mistake 3: No Reduction Strategy

Wrong: “We plan to reduce emissions.”

Right: Specific, quantified targets with implementation plans and budget allocation.

Mistake 4: Inconsistent Methodology

Wrong: Changing calculation methods each year.

Right: Use GMSF v1.2 consistently year over year. Document any methodology changes.

Mistake 5: Ignoring Supply Chain

Wrong: Only measuring direct platform emissions.

Right: Include all intermediaries (DSPs, SSPs, ad networks, data providers).

Penalties for Non-Compliance

Each EU member state sets its own penalties, but typical consequences include:

Financial penalties:

Fines up to 5% of global annual revenue
In some countries, daily penalties until compliance is achieved

Operational consequences:

Directors’ personal liability
Exclusion from public procurement
Difficulty accessing capital markets
Reputational damage

Real examples from 2025:

German automotive company: €12M fine for incomplete Scope 3 reporting
French retail chain: CEO personally fined €50K for misleading sustainability claims
Spanish bank: Excluded from €2B public sector contract due to non-compliance

The enforcement is real. Don’t assume you can wait.

Your 2026 Compliance Roadmap

Q1 2026: Foundation

Assign ownership (marketing + sustainability teams)
Inventory all advertising platforms and spend
Assess current data collection capabilities
Budget for tools and external support

Q2 2026: Measurement

Deploy GMSF v1.2-compliant measurement solution
Calculate baseline emissions for FY 2025
Document methodology
Identify data gaps

Q3 2026: Strategy

Set science-based reduction targets
Develop action plans (creative optimization, SPO, etc.)
Implement quick wins
Engage external auditor

Q4 2026: Reporting

Generate ESRS E1-compliant reports
Complete external audit
Integrate into annual sustainability statement
Prepare for FY 2027 reporting

Tools and Solutions

Carbon Intelligence for CSRD

Carbon Intelligence provides CSRD-ready advertising carbon measurement:

GMSF v1.2-aligned calculations
Automated data collection from all major platforms
ESRS E1 format templates
Audit-ready documentation
Multi-year trend tracking
External auditor support

Request CSRD compliance demo →

Alternative Approaches

Manual calculation: Use GMSF guidelines + spreadsheets (time-intensive, error-prone, difficult to audit)

Consultancy: Big 4 firms (expensive, limited ongoing support, typically €100K+ per year)

Platform tools: Google/Meta carbon dashboards (incomplete coverage, not audit-ready, don’t meet CSRD requirements)

For most companies, a specialized platform like Carbon Intelligence is the most efficient approach.

The Business Case

CSRD compliance isn’t just about avoiding penalties. Forward-thinking companies are turning it into a competitive advantage:

Benefits of early adoption:

Avoid penalties: Be ready before enforcement intensifies
Reduce costs: Carbon optimization reveals wasteful spend
Improve performance: Better targeting = better ROI
Attract investment: ESG-focused investors favor compliant companies
Win clients: B2B customers increasingly require sustainability commitments

Real example: A major European financial services company implemented GMSF-aligned carbon tracking in 2025. Results:

47% reduction in advertising emissions (year 1)
€2.8M cost savings from eliminated waste
22% improvement in ROAS
Full CSRD compliance achieved 4 months early
Featured in industry sustainability rankings

Key Takeaways

CSRD is mandatory for thousands of companies. Digital advertising emissions must be reported under Scope 3.
Omnibus I simplified requirements (December 2025) but maintained core disclosure obligations for FY 2027.
Use GMSF v1.2 for calculations. Spend-based methods overstate emissions by 450% and won’t pass audit.
Start now if you’re reporting in 2027. Data collection and methodology setup takes time.
Carbon reduction improves ROI. Most companies achieve 40%+ emissions reductions while maintaining or improving campaign performance.

The companies succeeding with CSRD are treating it as an optimization opportunity, not a compliance burden. They’re discovering that measuring carbon reveals inefficiencies they didn’t know existed.

Ready to get CSRD-compliant? Calculate your baseline emissions, set reduction targets, and implement optimization strategies. The sooner you start, the easier it gets.

While CSRD remains the dominant framework for European companies, US states are developing parallel obligations. Read our deep dive on US climate regulation and what it means for advertising →

Get CSRD-compliant carbon reporting →

Carbon Intelligence helps companies achieve CSRD compliance with GMSF v1.2-aligned carbon measurement, ESRS E1 reporting templates, and audit-ready documentation for digital advertising.