CSRD scope after Omnibus I is much narrower. An EU company or group now falls within mandatory reporting only if it has more than 1,000 employees and a net turnover above EUR 450 million. Both thresholds must be exceeded. A separate regime applies to certain non-EU groups.
The changes come from Directive (EU) 2026/470, part of the Omnibus I simplification package. The new scope applies to financial years starting on or after 1 January 2027. Member States must transpose the CSRD amendments by 19 March 2027, so national law still decides the details.
If your company prepared for the Corporate Sustainability Reporting Directive (CSRD) under the old rules, check your position before you change your plans. You may still be in scope, qualify for an exemption or no longer need your own sustainability statement. Your parent company, customers or lenders may still ask you for data.
CSRD thresholds: which EU companies and groups are in scope?
The revised test has two conditions. You need both:
- more than 1,000 employees on average during the financial year, and
- a net turnover above EUR 450 million.
For an EU parent company, the group test uses consolidated figures. A company can be below the thresholds on its own and still belong to a group that must report.
Two examples. A group with 1,200 employees and EUR 400 million net turnover does not meet the test. Neither does a group with 900 employees and EUR 600 million. Both may still receive data requests from a customer or parent company that reports.
Use the accounting definitions that apply to you when you calculate the figures.
CSRD reporting timeline: when do the requirements apply?
“First-wave companies” are those that started reporting under the CSRD for financial years beginning in 2024.
| Company or group | Position after Omnibus I | When to report |
| First-wave companies above both new thresholds | Still in scope | Continue reporting |
| First-wave companies that do not exceed both new thresholds | Out of the size-based scope from FY2027 | May still need to report for FY2025 and FY2026, unless their Member State applies the exemption |
| Other EU companies and groups above both thresholds | In scope | First report on FY2027, published in 2028 |
| Listed SMEs | Removed from mandatory scope | No mandatory CSRD report |
| Non-EU groups meeting the Article 40a conditions | Separate third-country regime | First report on FY2028, published in 2029 |
Publication years assume the financial year matches the calendar year. All rows are subject to the exemptions described below.
CSRD requirements for non-EU groups
A non-EU group falls under the separate regime in Article 40a of the Accounting Directive when it has:
- more than EUR 450 million net turnover in the EU in each of the last two financial years, and
- an EU subsidiary with more than EUR 200 million net turnover in the preceding financial year or, if there is no such subsidiary, an EU branch above the same threshold.
This regime has no employee threshold. The EU subsidiary or branch publishes the group’s sustainability report. EU subsidiaries may also have their own reporting obligations, which need a separate check.
The dedicated standards for this regime (ESRS-40a) are still in draft. EFRAG’s public consultation closed on 31 October 2026. Groups can also report under the full ESRS or recognized equivalent standards where the legal conditions are met.
CSRD exemptions: what should you check?
Subsidiaries covered by a parent’s report. A subsidiary may be exempt when its parent’s consolidated sustainability report covers it and the legal conditions are met, including what the subsidiary states in its own management report. Omnibus I extends this exemption to listed subsidiaries. Being included in a group report is not enough on its own.
Financial holding undertakings. An EU parent that meets the legal definition of a financial holding undertaking may opt out of consolidated sustainability reporting when its subsidiaries’ business models and operations are independent of one another. A similar option exists for non-EU parents. Subsidiaries may still have their own obligations.
First-wave companies leaving the scope. Member States may exempt them for financial years starting in 2025 or 2026. Check that your country has introduced the exemption and that it covers your company.
What changes for standards, assurance and EU Taxonomy reporting?
Revised ESRS from 2027. Delegated Regulation (EU) 2026/1563 sets out simplified European Sustainability Reporting Standards (ESRS) for financial years starting on or after 1 January 2027. Companies can apply them early for 2026, or keep the previous version with specific reliefs. Double materiality stays: you assess your impacts on people and the environment, and how sustainability matters affect your business financially.
Read our guide to the revised ESRS 2026
Limited assurance stays. Mandatory sustainability statements still need limited assurance from an independent assurance provider. Omnibus I dropped the planned move to reasonable assurance. The Commission must adopt limited assurance standards by 1 July 2027.
EU Taxonomy: check the rules separately. Taxonomy reporting under Article 8 is linked to the sustainability reporting requirements, but it has its own transition rules. For example, certain financial undertakings can temporarily opt out of detailed Taxonomy disclosures under strict conditions. The Commission explains this in Notice C/2026/2558.
What if your company is outside the CSRD scope?
You may still get sustainability data requests from customers, banks, investors or a parent company.
The EU Voluntary Standard, set out in Annex I of Delegated Regulation (EU) 2026/1560, gives you a simple framework for answering them, with a basic and a comprehensive module.
From financial years starting on or after 1 January 2027, the value chain cap protects companies with an average of no more than 1,000 employees in the previous financial year. For their CSRD reporting, larger companies cannot require more from them than the datapoints in Annex II. Protected companies can decline requests beyond that. The cap does not cover requests made for other legal purposes.
For requests outside CSRD reporting, financial institutions are encouraged to limit what they ask from companies with up to 1,000 employees to Annex I. This is guidance, not a binding cap.
CSRD scope assessment in four steps
- Identify the reporting entity. Look at the company on its own and, where relevant, at the consolidated group. For a non-EU parent, also check Article 40a.
- Apply the thresholds. Use the correct turnover, employee figures and financial year. Keep individual and consolidated figures apart.
- Check exemptions and timing. Review the parent-report, financial holding and first-wave exemptions under your national law.
- Record the decision. Note the legal basis, the figures, the period and the conclusion, and who will update it when the rules or your business change.
Then separate your own reporting duty from data requests by your parent, customers or lenders. That tells you what data to collect and who should own it.
Organizing the data behind your reporting
ESG Platform brings reporting data, responsibilities and supporting evidence into one workflow. Teams assign owners and deadlines, review information and keep a clear audit trail. Assurance providers get controlled access to data and evidence. Data is hosted in the EU.
Whether you prepare a mandatory statement or answer a business partner, you can trace every reported figure back to its source.
Talk to our experts about your reporting process.
CSRD scope after Omnibus I: frequently asked questions
Must EU companies exceed both CSRD thresholds?
Yes. An EU company or group must have more than 1,000 employees on average and a net turnover above EUR 450 million. Groups use consolidated figures.
If we are below the thresholds, can we stop reporting now?
Not necessarily. First-wave companies may still need to report for financial years starting in 2025 or 2026, unless their Member State grants the exemption. You may also need to provide data for your parent’s report.
When is the first report due for a company newly in scope?
For EU companies outside the first wave, the first reporting year starts on or after 1 January 2027. A report on calendar year 2027 is published in 2028.
Does the 1,000-employee threshold apply to non-EU groups?
Not under Article 40a. That regime uses EU turnover and the EU subsidiary or branch threshold. EU subsidiaries may still have their own obligations.
Can customers still ask for sustainability data?
Yes, but the purpose matters. From 2027, protected companies can decline CSRD-related requests that go beyond Annex II of the Voluntary Standard. Requests for other legal purposes are assessed separately.
Sources
- Directive (EU) 2026/470: reporting scope, exemptions, assurance and national transposition.
- Delegated Regulation (EU) 2026/1563: revised ESRS and application dates.
- Delegated Regulation (EU) 2026/1560: voluntary reporting and the value chain cap.
- EFRAG: ESRS-40a consultation: standards for certain non-EU undertakings.
Commission Notice C/2026/2558: EU Taxonomy disclosure rules and transition relief.