CSRD after the Omnibus: who has to report, and when
The EU’s 2025–26 simplification cut CSRD’s scope sharply. Here are the new thresholds for EU and non-EU groups, the reporting dates, and what smaller suppliers can still be asked for.
The Corporate Sustainability Reporting Directive (CSRD) requires large companies to report on sustainability using the European Sustainability Reporting Standards (ESRS). In 2025 the EU first delayed the later waves (the “stop-the-clock” directive) and then agreed the Omnibus simplification, which narrowed who is in scope. This guide sets out where things stand.
The short version
| Who | In scope if | First financial year | First report |
|---|---|---|---|
| EU groups and companies | More than 1,000 employees and over €450 million turnover | 2027 | 2028 |
| Non-EU groups | Over €450 million EU turnover (two years running) and an EU subsidiary or branch with over €200 million turnover | 2028 | 2029 |
| Companies already reporting (“wave 1”) | Keep reporting, unless your country uses the option to exempt companies that fall out of scope for 2025 and 2026 | Already reporting | Already reporting |
| Listed SMEs and smaller companies | Out of scope; can use the voluntary VSME standard | n/a | n/a |
Both size tests for EU companies are measured at group level, on consolidated figures. Meeting only one of them is not enough.
What changed
Fewer companies in scope
The original CSRD would have covered around 50,000 companies, including listed SMEs. The higher thresholds remove the large majority of them. Most mid-sized companies that were preparing for 2025 or 2026 reports are now out of scope.
Later dates
Companies that were due to start with financial year 2025 or 2026 were pushed back by the stop-the-clock directive. Under the new scope, EU companies that remain in scope start with financial year 2027.
Simpler standards
The ESRS are being revised to reduce the number of data points and make more of them voluntary. The plan for mandatory sector-specific standards was dropped. The revised standards are expected to apply to the first reports under the new scope.
Limited assurance only
Reports need limited assurance from an auditor or accredited assurance provider. The planned move to the stricter reasonable assurance was dropped. Read more in our guide to ESG assurance.
What if you are a supplier below the thresholds?
Large customers still need data from their value chain, especially for Scope 3 emissions. The simplification caps what in-scope companies can demand from businesses with fewer than 1,000 employees: requests should not go beyond what the voluntary VSME standard covers. In practice, expect questionnaires about energy use, emissions, workforce and governance, and keep that data ready in one place.
Non-EU groups
Non-EU parents are in scope only above €450 million of EU turnover for two consecutive years, and only if they also have a large EU subsidiary or branch (over €200 million turnover). Separate reporting standards for non-EU groups are still being written. Large EU subsidiaries can also be in scope on their own if they pass the EU thresholds.
How CSRD fits with other rules
- CSDDD (due diligence) now applies only to much larger companies (more than 5,000 employees and €1.5 billion turnover) from July 2029.
- ISSB-based rules in the UK, Singapore, Malaysia and Australia overlap with the climate parts of ESRS. See ESRS vs ISSB vs GRI.
- CBAM applies to importers of steel, aluminium, cement, fertilisers, electricity and hydrogen above 50 tonnes a year, whatever your size.
Getting ready
If you are in scope from 2027, a sensible order is:
- Confirm scope at group level with your finance team.
- Run a double materiality assessment to decide which topics you report on.
- Map the data you need against what you already collect, and close the gaps.
- Choose software and, if needed, an adviser. See our CSRD software buying guide.
- Do a dry run a year early and share it with your assurance provider.
Advisers who help with CSRD readiness
ERM
Sustainability consultancy advising on ESG strategy, climate and regulatory reporting.
Greenativity
German sustainability consultancy offering double materiality assessments, CSRD workshops and reporting support with its own Caribou software.
Systain
Hamburg sustainability consultancy focused on supply chains, climate and human rights for retail and consumer goods companies.
Sustainly
Czech ESG reporting and carbon accounting workspace for SMEs based on VSME and GRI, with physical climate risk screening.
Ordered by verified reviews and relevance. Listings are never ranked by payment. See all 20 providers
Official sources
This guide is general information, not legal, tax or investment advice. Rules change; check the official sources and talk to an adviser before you rely on it.
Related guides
What assurance providers ask for in a sustainability report
The evidence, documentation and controls an assurance provider typically expects to see when reviewing a sustainability report, and how to prepare before they arrive.
How-to guideHow to prepare your first VSME sustainability report
A practical walkthrough for small and mid-sized companies answering customer and bank requests with a VSME-style report: which module, what data, who owns what, and how to avoid over-reporting.
How-to guideDouble materiality assessment: a step-by-step process
A working process for running a double materiality assessment, from scoping and stakeholder input to scoring, sign-off and documentation, with the evidence an auditor will want to see.