Report · 06
CSRD & ESRS
Europe’s sustainability disclosure — after the Omnibus.
In short
CSRD is the EU’s sustainability reporting directive. The Omnibus reform of February 2026 raised its thresholds sharply — to more than 1,000 employees and more than €450m turnover — cutting the number of companies in scope by around 85%, while keeping double materiality, assurance and the value-chain data demands intact.
What it is
The Corporate Sustainability Reporting Directive is the EU’s mandatory sustainability reporting regime, reported under the European Sustainability Reporting Standards (ESRS), built on double materiality and subject to assurance.
Why it matters
The Omnibus package narrowed CSRD to the largest companies but kept double materiality and assurance intact — and large non-EU groups above the EU turnover threshold remain in scope. Scope narrowed; direction did not.
The change is now law: Omnibus I — Directive (EU) 2026/470 — was adopted in February 2026 and entered into force in March 2026, raising the CSRD threshold to more than 1,000 employees and over €450m net turnover (both required). Analysis suggests this cuts the number of in-scope companies by roughly 85% (Morrison Foerster; ERM analysis, 2026). Revised-scope reporting applies for financial years from 1 January 2027, with limited assurance retained (Accountancy Europe, 2026).
What & how we do it
The work, in the order we do it.
- Confirm whether and when you’re in scope
- Run a defensible double materiality assessment
- Complete an ESRS gap analysis and build the data
- Prepare for assurance
- Deliver a filing-ready report that interoperates with IFRS S1/S2 and GRI
Standards & frameworks
- CSRD
- ESRS
- Aligned to IFRS S1/S2 and GRI
The rules, as they stand
What the regulation actually says.
| Position as at September 2026 | |
|---|---|
| Governing law | Directive (EU) 2026/470 (Omnibus I) — adopted 24 February 2026, in force 18/19 March 2026DLA Piper; Norton Rose Fulbright; PwC, 2026 |
| New threshold | More than 1,000 employees and more than €450m net turnover — both requiredMorrison Foerster; Sprih/ERM, 2026 |
| Previous threshold | 250 employees / €50m turnoverMorrison Foerster, 2026 |
| Effect on scope | Around 85% fewer companies in scopeMorrison Foerster; Sprih/ERM, 2026 |
| Non-EU groups | Still in scope above €450m EU turnover, with a €200m subsidiary or branch thresholdRegulation Tomorrow, 2026 |
| Retained | Double materiality and limited assurance — a limited-assurance standard is due by 1 July 2027Accountancy Europe; Sprih, 2026 |
Key dates
- 24 February 2026Omnibus I adopted by the Council.
- 26 February 2026Published as Directive (EU) 2026/470.
- 18/19 March 2026In force.
- 1 January 2027Revised-scope reporting applies for financial years beginning on or after this date.
- 1 July 2027Limited-assurance standard due.
- 26 July 2029CSDDD applies, at above 5,000 employees and €1.5bn turnover.
Common questions
Only if you clear both of the raised thresholds — more than 1,000 employees and more than €450m net turnover. The previous test was 250 employees or €50m, so around 85% of previously in-scope companies fell out.
It can. Non-EU groups remain in scope above €450m of EU turnover, with a €200m threshold at subsidiary or branch level.
No. Double materiality and limited assurance were both retained. The scope narrowed; the framework did not.
For financial years beginning on or after 1 January 2027. The limited-assurance standard is due by 1 July 2027.
Usually there is. Value-chain data requests reach far below the reporting thresholds — your in-scope customers still have to report on you. Falling out of direct scope rarely removes the data obligation, it just changes who asks.
Its thresholds rose too, to more than 5,000 employees and €1.5bn turnover, applying from 26 July 2029.
Map your CSRD obligations.
Give us your EU turnover and headcount and we will tell you, plainly, whether the Omnibus took you out of scope.
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