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European Union

CSRD and ESRS, narrowed

Omnibus I cut the EU’s sustainability reporting law back to the largest companies, and the simplified ESRS apply from 2027. Those still in scope report with double materiality, which goes further than ISSB.[4],[6]

Check your scope →How ESRS relates to ISSB
Checked 6 October 2026Directive 2026/470Regulation 2026/1563
What changed

Fewer companies, fewer datapoints

Omnibus I, Directive (EU) 2026/470, was adopted by the Council on 24 February 2026 and entered into force on 18 March 2026. Member states have twelve months to transpose its CSRD changes.[4],[5]

The Commission must adopt limited-assurance standards by 1 July 2027; the move to reasonable assurance has gone.[5]

The first wave, the large public-interest entities that reported on 2024, stays in scope only where it meets the new thresholds.[1],[5]

1,000+Employees, the first test for EU companiesCouncil of the EU[4]
€450mNet turnover, the second test, and the EU turnover test for non-EU groupsCouncil of the EU[4]
61%Cut in mandatory ESRS datapointsEFRAG[7]
2027Simplified ESRS apply to financial years from 1 JanuaryReg. (EU) 2026/1563[6]
Your figures

Are you in scope?

Move the sliders to your group’s figures. EU parents are tested on employees and turnover; non-EU parents on EU turnover and the size of their largest EU subsidiary or branch.

Out of scope does not mean out of reach. Customers and banks in scope will still ask for data, which is why the EU published a voluntary standard for smaller companies alongside the ESRS.[7]

Where is the group’s parent?

Likely in CSRD scope

Report

Both tests must be met: ✓ 1,200 employees is over 1,000; ✓ €600m net turnover is over €450m.

Thresholds from Omnibus I as agreed by the Council on 24 February 2026. Member states transpose by March 2027; national law decides the detail.

Before and after

The CSRD, then and now

The 2022 directive and its 2023 size adjustment against the regime after Omnibus I.[1],[2],[4]

TopicCSRD as adopted (2022)After Omnibus I (2026)
EU companiesLarge undertakings meeting two of three tests (over 250 employees, €50m turnover, €25m balance sheet), plus listed SMEsOver 1,000 employees and over €450m net turnover
Non-EU groupsOver €150m EU turnover, with an EU subsidiary or branch over the size testsOver €450m EU turnover, with an EU subsidiary or branch over €200m turnover
StandardsESRS Set 1 (2023)Simplified ESRS, 61% fewer mandatory datapoints
AssuranceLimited, with a path to reasonableLimited only; reasonable assurance dropped
Listed SMEsIn scope, with an opt-outOut of mandatory scope; voluntary standard available
Timeline

EU dates, in order

From stop-the-clock to the first assurance standards.[3],[6]

  1. 16 Apr 2025EU
    Stop-the-clock directive delays CSRD waves 2 and 3 by two years
  2. 26 Feb 2026EU
    Omnibus I (Directive 2026/470) published: CSRD narrowed to 1,000+ employees and €450m+ turnover
  3. 21 Sep 2026EU
    Simplified ESRS published as Delegated Regulation 2026/1563
  4. 10 Nov 2026EU
    Simplified ESRS enter into force
  5. 1 Jan 2027EU
    Simplified ESRS apply to financial years starting on or after this date
  6. 1 Jul 2027EU
    Deadline for the Commission to adopt limited-assurance standards
Questions

CSRD, answered

Which companies are in CSRD scope after Omnibus I?

EU companies with more than 1,000 employees and more than €450m net turnover. Non-EU groups are in scope with more than €450m EU turnover and an EU subsidiary or branch above €200m.[4],[5]

When do the simplified ESRS apply?

Delegated Regulation (EU) 2026/1563 was published on 21 September 2026 and enters into force on 10 November 2026. It applies to financial years beginning on or after 1 January 2027, and companies may opt in for 2026.[6],[7]

What was the stop-the-clock directive?

Directive (EU) 2025/794, published on 16 April 2025, pushed CSRD reporting back two years for the second and third waves, the large non-listed companies and listed SMEs, while Omnibus I narrowed the scope.[3]

Is double materiality still required?

Yes. The CSRD still asks for both directions: how sustainability matters affect the company, and the company’s impacts on people and the environment.[1] The simplified ESRS make the assessment lighter but keep the principle.[7]

Sources

Where this comes from

Primary sources unless labelled secondary.

  1. [1]Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive)Official Journal of the EU · 16 December 2022
  2. [2]Commission Delegated Directive (EU) 2023/2775 (adjustment of size criteria)Official Journal of the EU · 21 December 2023
  3. [3]Directive (EU) 2025/794 ("stop-the-clock")Official Journal of the EU · 16 April 2025
  4. [4]Council signs off simplification of sustainability reporting and due diligence requirementsCouncil of the EU · 24 February 2026
  5. [5]First omnibus package on sustainability: amending CSRD and CSDDD (Legislative Train)European Parliament
  6. [6]Commission Delegated Regulation (EU) 2026/1563 (revised ESRS)Official Journal of the EU · 21 September 2026
  7. [7]European Commission adopts revised ESRS and voluntary sustainability reporting standardEFRAG · 22 September 2026