EU sustainability reporting · CSRD + Omnibus

Are you still in scope of CSRD after the Omnibus?

The Omnibus reforms narrowed CSRD sharply: reporting now applies only to companies with over 1,000 employees AND over EUR 450M turnover, listed SMEs are removed, and the reporting waves were pushed back two years. Pick your size and wave to see where you stand.

Check your CSRD scope

Computed in your browser. This reflects the EU directives after the Omnibus — a fast-moving area; verify the binding thresholds on EUR-Lex.

Check your CSRD scope

Non-EU groups with EU activity have separate EU-turnover/branch tests — routed to 'seek advice'.

The post-Omnibus gate is more than 1,000 employees.

The post-Omnibus gate is more than EUR 450 million — confirm the binding figure on EUR-Lex.

Wave 1 = first reporting FY2024; wave 2 = FY2025; wave 3 = listed SMEs FY2026.

Relevant for the wave-one transition exemption.

CSRD scope verdict

In scope — CSRD reporting applies

You meet the post-Omnibus size gate (over 1,000 employees AND over EUR 450M net turnover) and are not an excluded SME, so CSRD sustainability reporting applies. Confirm your first reporting year against the binding directive text.

Things to know

  • The size gate is more than 1,000 employees AND more than EUR 450 million net turnover (both must be met). These are the binding figures circulating after the Omnibus — confirm them in the directive text on EUR-Lex before relying on them.
  • Confirm your first reporting year and the applicable ESRS — newly in-scope companies should check the directive's transitional provisions.
  • This reflects the EU directives (2022/2464 as amended by 2025/794 + 2026/470), NOT any one Member State's transposition — national application dates may differ and transposition is still rolling out in 2026.

The rule, in one line

After the Omnibus reforms (Directive (EU) 2022/2464 as amended by Dir (EU) 2025/794 'stop-the-clock' and Dir (EU) 2026/470 'Omnibus I'), CSRD sustainability reporting applies only to undertakings with on average more than 1,000 employees AND net turnover above EUR 450 million; listed SMEs are removed from scope. The reporting waves were postponed two years (wave 2 to FY2027, wave 3 to FY2028), and an optional Member-State transition exemption spares FY2025 and FY2026 only for former wave-one companies that no longer meet the new thresholds — wave-one companies still above them keep reporting. This is fast-moving EU law and reflects the directive, not any one Member State's transposition — confirm the binding thresholds against EUR-Lex.

Reviewed 2026-06-15 against EUR-Lex and the European Commission. CSRD is fast-moving EU law — it changed twice in about a year — so the 1,000-employee / EUR 450M figures are linked out to the binding directive text rather than asserted, and non-EU group structures route to 'seek advice'.

Scope + wave: a CSRD scope decision — am I still in after the Omnibus (over 1,000 employees AND over EUR 450M net turnover), and if so which wave and first reporting year (FY2027 / FY2028 after the two-year delay).
  • Size gatePost-Omnibus, mandatory CSRD reporting applies only to undertakings with on average more than 1,000 employees AND net turnover above EUR 450 million — both must be met. These are the figures circulating after the Omnibus; confirm the binding numbers on EUR-Lex.
  • Dropped outListed SMEs (and micro/small companies) were removed from CSRD scope by the Omnibus, and many former wave-one companies that no longer meet the raised thresholds fall out — only the voluntary VSME standard remains for SMEs that choose to report.
  • TimingThe 'stop-the-clock' directive postponed the reporting waves two years: wave 2 first reports for FY2027 and wave 3 for FY2028. An optional Member-State exemption spares FY2025/FY2026 only for former wave-one companies that no longer meet the new size gate.

Official sources:

Last reviewed 2026-06-15 — verified against Directive (EU) 2026/470, Directive (EU) 2025/794 and the European Commission. Informational, not legal or accounting advice; scope per Directive (EU) 2022/2464 as amended by the 2025 Omnibus (Dir (EU) 2025/794 + 2026/470), not any one Member State's transposition.

What this tool is — and isn't

This checker routes the post-Omnibus CSRD scope position from your company type, size and original wave under Directive (EU) 2022/2464 as amended by Dir (EU) 2025/794 and Dir (EU) 2026/470, using EUR-Lex + the EC finance and European Parliament pages. This is a fast-moving area that changed twice in about a year, and the binding article text of the latest amendment could not be machine-read in full — so the 1,000-employee / EUR 450M thresholds and especially the non-EU group / branch-turnover tests are linked out for the binding figure rather than asserted, and non-EU structures route to 'seek advice'. It reflects the EU directive, not any one Member State's transposition (still rolling out in 2026). It does not establish your company's definitive status. It is an estimate and orientation, not legal or accounting advice. Verify against the linked official sources.

CSRD post-Omnibus rules last reviewed June 2026.Rules verified against EUR-Lex, the EC and the European Parliament (2026-06-15).

How the determination works

1. Company type + non-EU routing

Non-EU groups with EU activity are routed to 'seek advice' (separate EU-turnover/branch tests); listed SMEs and micro/small companies are out of scope (removed by the Omnibus).

2. The post-Omnibus size gate

EU companies must meet BOTH thresholds — on average more than 1,000 employees AND net turnover over EUR 450 million. If either is below, mandatory CSRD reporting does not apply. The binding figures are linked out to EUR-Lex.

3. Wave timing

Among in-scope companies, the original wave sets the timing: wave 1 companies that still meet the new thresholds keep reporting (only former wave-1 companies that drop below the thresholds may get the optional FY2025 + FY2026 Member-State exemption); wave 2 is postponed to FY2027; wave 3 to FY2028. Newly in-scope companies confirm their first year against the directive.

Frequently asked questions

What changed with the Omnibus?
The Omnibus reforms (Dir (EU) 2025/794 'stop-the-clock' and Dir (EU) 2026/470) raised the CSRD size gate to over 1,000 employees AND over EUR 450M net turnover, removed listed SMEs, postponed the reporting waves two years, and let Member States grant an optional FY2025/FY2026 transition exemption to former wave-one companies that no longer meet the new thresholds (those that still do must keep reporting).
What are the new thresholds?
An EU company is in scope only if it has on average more than 1,000 employees AND net turnover over EUR 450 million — both must be met. These are the figures circulating after the Omnibus; confirm the binding numbers in the directive text on EUR-Lex.
Are listed SMEs still in scope?
No. The Omnibus removed listed SMEs from CSRD scope — there is no residual mandatory CSRD duty. Only the voluntary VSME standard remains available for SMEs that choose to report.
When do the postponed waves report?
After the two-year 'stop-the-clock' postponement, wave 2 first reports for FY2027 and wave 3 for FY2028. Wave 1 companies that still meet the new thresholds keep reporting; only former wave-1 companies that no longer meet them may get the optional FY2025/FY2026 transition exemption, where their Member State allows it.
I'm a non-EU group with EU sales — am I in scope?
Non-EU groups with EU activity are caught by separate EU-turnover and branch/subsidiary tests that this checklist does not resolve, and figures circulating in summaries are not asserted here. The tool routes you to 'seek advice' — get specialist help and check the binding text.
Is this legal advice?
No. This is a fast-moving area and the tool routes the position from your inputs while linking to the binding directive text; it reflects the EU directive, not national transposition, and does not establish your definitive status. It is orientation, not legal or accounting advice. Verify against the linked official sources.

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