Which ESRS must I report against?

CSRD applicability — frequently asked questions

What changed about CSRD scope under the adopted Omnibus?

The Omnibus I directive, adopted by the Council on 24 February 2026 and published in the Official Journal on 26 February 2026, raised the scope bar for EU undertakings to more than 1,000 employees AND more than €450 million net turnover (both conditions, in two consecutive financial years). The previous large-undertaking test (two of: 250 employees, €50M turnover, €25M balance sheet) no longer determines CSRD scope. The change removes roughly 90% of companies from scope (the European Commission's original 2025 proposal cited around 80%; no official absolute company count was published).

I have over 1,000 employees but under €450M turnover — am I in scope?

No. The two thresholds are conjunctive: you must exceed BOTH the 1,000-employee and the €450M-net-turnover figures in two consecutive financial years. Exceeding only the employee count (common in labour-intensive sectors such as logistics, facilities management, agriculture, and retail) does not bring you into CSRD scope.

Are listed SMEs still in scope?

No. Under the adopted Omnibus, listed small and medium-sized enterprises are fully exempt — a substantial shift from the original framework. The mandatory ESRS LSME standard was discontinued. Listed SMEs may report voluntarily using the VSME standard if they choose.

When is the first reporting year?

For wave-2 large undertakings newly in scope under the adopted Omnibus, the first reporting financial year is FY 2027 (reports published in 2028), following the stop-the-clock Directive (EU) 2025/794. Non-EU groups in scope report from FY 2028. Large public-interest entities with over 500 employees that already entered scope under the original CSRD wave 1 began reporting for FY 2024.

What assurance level is required?

Limited assurance only. The adopted Omnibus dropped the planned move from limited to reasonable assurance; the upgrade is removed, not merely deferred.

Has my member state transposed the Omnibus yet?

No member state has completed Omnibus transposition. The directive entered into force on 18 March 2026 with a transposition deadline of 19 March 2027, so the status is 'pending' across all 27 member states until national transposing acts are published. Always confirm against the national official journal before filing.

When does a non-EU (third-country) group fall into scope?

A non-EU group is in scope if it generated more than €450M net turnover in the EU in two consecutive financial years AND has either a large or listed EU subsidiary, or an EU branch with net turnover above €200M. The applicable standard is the third-country ESRS (NESRS) and the first reporting year is FY 2028.

Is this tool legal advice?

No. It is a deterministic orientation tool based on the cited public sources. Final CSRD scope determination rests with your statutory auditor and the competent national authority. Use the verdict to scope your assessment, not as a substitute for professional advice.

Related EU seller-compliance checks

Other guardrails for EU market obligations:

• CSRD scope & Omnibus wave check — am I in scope and which reporting wave
• Green Claims Directive checker — substantiate environmental marketing claims
• EUDR due-diligence statement check — deforestation-free supply chains
• All EU seller-compliance tools at SellerGuardrails