Who Must Report Under CSRD Now? The 2026 Scope, Explained

After the Omnibus, CSRD applies only to companies with more than 1,000 employees and at least €450 million net turnover, for financial years beginning on or after 1 January 2027. Most previously in-scope mid-sized companies now fall outside the mandate.

Who has to report under CSRD in 2026?

Only large companies exceeding both thresholds: more than 1,000 employees on average and at least €450 million in net turnover. Companies below either threshold are outside the mandatory scope. The narrowed scope applies for financial years beginning on or after 1 January 2027.

Note that this is an "and" test, not an "or" test. You need to exceed both the employee count and the turnover figure. A 1,200-person company with €300 million in turnover does not meet the turnover threshold and is therefore outside scope.

What were the old CSRD thresholds?

Before the Omnibus, CSRD reached large public-interest entities with more than 500 employees, and then large undertakings meeting two of three criteria: more than 250 employees, €50 million turnover, or €25 million total assets. The Omnibus raised the floor substantially.

The gap between those two regimes is why so many companies feel stranded. A 400-person company with €80 million in turnover was clearly in scope under the original CSRD and spent 2023 and 2024 preparing accordingly. Then the simplification signals arrived and preparation across the market stalled. Under the current rules, that company has no reporting obligation at all.

What is the stop-the-clock measure?

Stop-the-clock is the fast-tracked part of the Omnibus that delayed CSRD start dates by two years. Companies expected to publish their first report in 2026, covering financial year 2025, are now expected to report in 2028, covering financial year 2027.

It was passed separately and quickly, ahead of the full Omnibus package, because companies needed certainty before their reporting deadlines arrived. That is why you may remember two different Omnibus announcements.

I already reported under CSRD. Do I still have to?

Possibly not. Member States may exempt existing Wave 1 companies from CSRD obligations for financial years 2025 and 2026 if they fall below the revised 1,000-employee threshold. Whether that exemption applies to you depends on your Member State.

This is the awkward group: companies that qualified under the old rules as large public-interest entities with more than 500 employees, already built the reporting machinery, already published, and now sit under the new threshold. Check how your Member State implemented the transitional option before you assume either way.

What about non-EU companies?

Third-country undertakings are in scope when the parent generates more than €450 million net turnover in the EU, and has an EU subsidiary or branch above the €200 million threshold. The tests apply to EU-generated turnover, not global turnover.

For most non-EU groups this narrows exposure considerably. It also shifts the practical question from "does the group report" to "which EU entity triggers the test", which is a corporate structure question as much as a sustainability one.

I'm outside CSRD scope. Do I have to report anything?

Not legally. But customers, banks and investors still request ESG data, and the Voluntary Standard (VS, formerly VSME) is the format designed for that situation. It also acts as a value-chain cap, limiting what large customers can demand from you.

This is where most mid-sized companies actually land. The obligation is gone, the requests are not. Reporting against VS gives you one standard answer for every customer questionnaire, and a defensible basis for declining anything beyond it. See what the Omnibus changed, or go straight to whether the Voluntary Standard suits your company.

How do I check whether I'm in scope?

Compare your average employee count and net turnover for the financial year against both thresholds. If you exceed more than 1,000 employees and at least €450 million turnover, you are in scope from FY2027. If you fall below either, you are not.

If you are close to the line, or your headcount fluctuates, the safe move is to build a reporting baseline anyway. The data you would need for VS is a subset of what CSRD would demand, so the work is not wasted in either direction.

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Frequently asked questions

What is the CSRD threshold after the Omnibus?
More than 1,000 employees and at least €450 million net turnover, applying to financial years beginning on or after 1 January 2027.

Is the CSRD abolished?
No. The CSRD still exists and still applies to the largest companies. The Omnibus narrowed its scope and delayed its timelines, it did not repeal it.

Do companies under 1,000 employees have to report sustainability data?
Not under CSRD. Many still report voluntarily under the Voluntary Standard (VS, formerly VSME), because customers, banks and investors request the data.