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.
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 a transition exemption spares wave-one companies from reporting for FY2025 and FY2026. This is fast-moving EU law and reflects the directive, not any one Member State's transposition — confirm the binding thresholds against EUR-Lex.
Official sources: Directive (EU) 2026/470 · Directive (EU) 2025/794 · EC — Corporate sustainability reporting
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.
Per-company memo
CSRD scope memo (PDF) · €29
A print-ready pack for one company: the scope verdict, the size-gate analysis, the wave timing + first reporting year, the transition exemption, and source links to the binding directive text — for your governance file.
This is guidance, not legal or accounting advice. CSRD is fast-moving; the export restates the position for your inputs and links to the binding text, which you should confirm.
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.
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 gets a FY2025 + FY2026 transition 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 gave wave-one companies a transition exemption for FY2025 and FY2026.
- 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 (already FY2024 reporters) is relieved for FY2025 and FY2026 under the transition exemption.
- 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.