Free tool

CSRD Scope Checker

Not sure if the CSRD applies to your business after the Omnibus? Answer a few plain-English questions and get a tailored steer: whether it applies, on what basis, when you would first report, and what to do next.

Step 1 of 1

Where does your business sit relative to the EU?

CSRD scope after the Omnibus turns first on what kind of entity you are. An EU undertaking is tested on its own size; a non-EU parent is tested on its EU footprint; a smaller supplier is usually out of mandatory scope but may be asked for data.

The short version

How CSRD scope works after the Omnibus

Three things decide whether the directive lands on you: what kind of entity you are, your size, and your EU footprint. Here is each in plain English.

TL;DR

After the Omnibus, an EU undertaking is in mandatory CSRD scope only if it exceeds both more than 1,000 employees and more than EUR 450 million net turnover. Listed SMEs are out (they can use voluntary VSME). Non-EU parents are caught above EUR 450 million EU turnover plus a qualifying EU subsidiary or branch. Newly in-scope EU firms first report for FY2027, published in 2028.

The new EU test: 1,000 employees AND EUR 450m turnover

The single biggest Omnibus change is scope. An EU undertaking is now in mandatory scope only if it exceeds both more than 1,000 employees (average over the financial year) and more than EUR 450 million net turnover, assessed at individual or group level. This is a cumulative AND test on two metrics: the old two-of-three test (250 employees, EUR 50m turnover, EUR 25m balance sheet) is superseded, and the balance-sheet criterion is dropped. Council of the EU, 24 Feb 2026

The Commission claims this removes around 80 percent of previously covered companies, taking the population from roughly 50,000 down to about 5,000. Listed SMEs are removed from mandatory scope and, like other smaller companies, can report voluntarily using the VSME standard instead.

Non-EU parents: tested on their EU footprint

A non-EU (third-country) parent is in scope if its group generates more than EUR 450 million of net turnover in the EU for two consecutive years (raised from EUR 150 million), and it has either an EU subsidiary that is a large undertaking or an EU branch with net turnover above EUR 200 million (raised from EUR 40 million). These groups report at group level under the dedicated standards for non-EU groups (N-ESRS). European Commission, CSRD overview

When you report

Newly defined in-scope EU companies report for financial year 2027, with the first report published in 2028. Non-EU groups report for FY2028, published in 2029. Former Wave 1 companies (large public-interest entities with more than 500 employees) that already reported for FY2024 and remain above the thresholds simply continue; those now below may get a Member-State-optional pause for FY2025 and FY2026, with a mandatory exit from FY2027. Directive (EU) 2022/2464, as amended

Two parts are still moving

The new thresholds are confirmed law (Directive (EU) 2026/470, in force 18 March 2026), but they must be transposed into national law by 19 March 2027, and penalties and transition options differ by Member State. Separately, the revised "ESRS 2.0" delegated act, which cuts mandatory datapoints by roughly 60 to 70 percent, was in public consultation (6 May to 3 June 2026) and is not yet adopted. We track both in The CSRD Brief.

Scope questions people ask

Who has to comply with CSRD after the Omnibus?

After the Omnibus, an EU undertaking is in mandatory CSRD scope only if it exceeds both more than 1,000 employees and more than EUR 450 million net turnover, measured at individual or group level. This cumulative AND test replaced the old two-of-three test (250 employees, EUR 50m turnover, EUR 25m balance sheet). The balance-sheet criterion was dropped entirely.

Are SMEs and listed SMEs in scope after the Omnibus?

No. Listed SMEs were removed from mandatory CSRD scope, and smaller companies that miss the thresholds are out of mandatory scope. They can report voluntarily using the VSME (Voluntary SME) standard if they choose. The value-chain cap also protects them: an in-scope customer may not demand data beyond VSME from value-chain partners with fewer than 1,000 employees.

When do newly in-scope companies first report?

Newly defined in-scope EU companies (more than 1,000 employees and more than EUR 450 million turnover) report for financial year 2027, with the first report published in 2028. Non-EU groups that meet the higher thresholds report for FY2028, published in 2029. Former Wave 1 companies that already reported for FY2024 and remain above the thresholds simply continue.

Does CSRD apply to non-EU (third-country) companies?

It can. A non-EU parent is in scope if its group generates more than EUR 450 million of net turnover in the EU for two consecutive years (raised from EUR 150 million) and it has either an EU subsidiary that is a large undertaking or an EU branch with net turnover above EUR 200 million (raised from EUR 40 million). Such groups report at group level under the dedicated non-EU standards (N-ESRS) from FY2028.

I am a small supplier being asked for CSRD data. Do I have to provide it?

Usually not beyond the VSME standard. The Omnibus added a value-chain cap: an in-scope company may not require sustainability data beyond what the voluntary VSME standard specifies from value-chain partners with fewer than 1,000 employees. You can provide VSME-level information and decline requests that go further.

This is guidance to help you understand the CSRD, not legal advice. CSRD is a directive transposed country by country, and some parts are still in flux. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Directive (EU) 2022/2464 (CSRD) on EUR-Lexretrieved 8 Jun 2026
  2. [2]Council of the EU, sign-off of the sustainability reporting simplification (Omnibus), 24 Feb 2026retrieved 8 Jun 2026
  3. [3]European Commission, Corporate sustainability reportingretrieved 8 Jun 2026