What does the CSRD ask of your company after the Omnibus?

Both values must be exceeded together: an average of more than 1,000 employees during the financial year and a net turnover above EUR 450 million, for the undertaking itself or for its group on a consolidated basis.

The Directive has been amended twice. The Stop-the-clock Directive (EU) 2025/794 postponed the reporting dates, and Directive (EU) 2026/470 (Omnibus I), in force since 18 March 2026, replaced the size test, removed listed SMEs and kept assurance at the limited level. Both are directives, so companies are bound once national law transposes them; for Directive (EU) 2026/470 the deadline is 19 March 2027.

This page sets out who reports and from which financial year, what the report contains under the European Sustainability Reporting Standards (ESRS), how reporting is checked, how national law fits in and where the rules stand on 29 October 2026. Each part has its own page, and the acronyms used here are explained in the CSRD and ESRS glossary.

What Is the CSRD?

The CSRD is Directive (EU) 2022/2464 of 14 December 2022, which amended the Accounting Directive 2013/34/EU, the Transparency Directive 2004/109/EC, the Audit Directive 2006/43/EC and the Audit Regulation (EU) No 537/2014 to make companies report sustainability information under common EU standards. Its reporting rules sit inside the Accounting Directive, so they are cited as articles of Directive 2013/34/EU. Article 2(18) defines sustainability reporting as reporting information related to sustainability matters in accordance with Articles 19a, 29a and 29d. Sustainability matters are, under Article 2(17), environmental, social and human rights, and governance factors, including the sustainability factors defined in Article 2(24) of Regulation (EU) 2019/2088.

The CSRD is a directive, not a regulation. Its eight articles bind the Member States, which transpose Articles 1 to 3 into national law, and companies are bound by that national law; only Article 4, which amends the Audit Regulation, applies directly. The ESRS work differently: they are Commission delegated regulations, binding in their entirety and directly applicable in every Member State without transposition.

The Directive, Its Predecessor and the Acts That Amended It

The CSRD replaced the Non-Financial Reporting Directive 2014/95/EU and has since been amended by two directives and completed by four Commission delegated regulations. The Commission proposed it as COM(2021) 189 on 21 April 2021; Parliament adopted its first-reading position on 10 November 2022, the Council followed on 28 November 2022 and the act was signed on 14 December 2022. The CSRD has 84 recitals, and it inserted Articles 19a, 29a, 29b, 29c, 29d, 40a to 40d and 48i into Directive 2013/34/EU. Its predecessor, the NFRD, applied to large public-interest entities exceeding 500 employees from financial years starting in 2017.

The two amending directives started as Commission proposals of 26 February 2025: COM(2025) 80 became the Stop-the-clock Directive (EU) 2025/794 and COM(2025) 81 became Directive (EU) 2026/470. Directive (EU) 2026/470 inserted Articles 29ca, 29e and 29f into Directive 2013/34/EU and deleted Article 29c. The four delegated regulations hold the reporting standards: the first set of ESRS, its quick fix, the revised ESRS and the voluntary standard. Table 1 lists these acts with their Official Journal reference, their date of effect and the page that covers each.

Is the Directive Still in Force after 2026?

Yes: Directive (EU) 2022/2464 has been in force since 5 January 2023 and remains in force as amended, most recently by Directive (EU) 2026/470, in force since 18 March 2026. The Omnibus did not repeal the CSRD. It narrowed the scope to undertakings and groups above both new values, moved the first reporting years of large undertakings and deleted the listed-SME regime, while the duty to report in the management report under the ESRS stays in place.

EUR-Lex holds a consolidated version of the CSRD dated 18 March 2026 (CELEX 02022L2464-20260318), which includes both amending directives; consolidated versions are documentation tools without legal effect, and only the texts published in the Official Journal are authentic. Two transposition deadlines apply to the Member States: 6 July 2024 for the CSRD itself (Article 5(1) of Directive (EU) 2022/2464) and 19 March 2027 for Articles 1 to 3 of Directive (EU) 2026/470 (its Article 5(1)).

What Changed in 2025 and 2026

Two directives changed the CSRD after 2024: the Stop-the-clock Directive (EU) 2025/794 moved the first reporting year of large undertakings to financial year 2027, and Directive (EU) 2026/470 replaced the size test, removed listed SMEs, raised the non-EU values, capped value-chain requests and kept assurance at the limited level. Directive (EU) 2025/794 of 14 April 2025 entered into force on 17 April 2025 and had to be transposed by 31 December 2025 (Article 3(1)). It moved large undertakings outside wave 1 from financial year 2025 to financial year 2027, and listed SMEs from financial year 2026 to financial year 2028, a step that Directive (EU) 2026/470 later deleted together with the listed-SME scope. Recital 3 of Directive (EU) 2025/794 gives the reason: while the simplification initiatives were ongoing, and to avoid the undertakings due to report for financial years beginning on or after 1 January 2025 and 1 January 2026 "incurring unnecessary and avoidable costs", their reporting requirements were postponed by two years.

Directive (EU) 2026/470 of 24 February 2026 followed a political agreement in December 2025 and made the content changes, which Table 2 maps to their amending provisions. The "before" column gives the rule before Directive (EU) 2026/470, as it applied where transposed; the size values in it are those of Delegated Directive (EU) 2023/2775, which raised the Accounting Directive size criteria from financial year 2024. The authentic text of Directive (EU) 2026/470 (CELEX 32026L0470) is published on EUR-Lex.

Who Has to Report from Financial Year 2027

From financial years starting on or after 1 January 2027, the CSRD applies to undertakings and groups that exceed both a net turnover of EUR 450 million and an average of 1,000 employees, to banks and insurers of any legal form above the same values, and to issuers on an EU regulated market above them. The first reports under the new scope are due in 2028, and each category is set out under who must report under the CSRD. Credit institutions and insurance undertakings are covered regardless of legal form only when they exceed both values (Article 1(3) of Directive 2013/34/EU as amended by Article 2(1)(a) of Directive (EU) 2026/470). Issuers follow the same values (CSRD Article 5(2), third subparagraph, as amended by Article 3(1)(b)).

Investment funds and the European Financial Stability Facility are excluded from Articles 19a, 29a and 29d altogether: UCITS and alternative investment funds within the meaning of Article 2(12)(b) and (f) of Regulation (EU) 2019/2088, and the European Financial Stability Facility (Article 1(4) of Directive 2013/34/EU as replaced by Article 2(1)(b) of Directive (EU) 2026/470).

Undertakings and Groups above Both Size Values

An undertaking reports if, on its balance sheet date, it exceeds a net turnover of EUR 450 million and an average number of 1,000 employees during the financial year (Article 19a(1) of Directive 2013/34/EU as replaced by Article 2(4)(a) of Directive (EU) 2026/470). A parent undertaking applies the same two values to its group on a consolidated basis (Article 29a(1) as replaced by Article 2(5)(a)), and the parent's own size does not decide the group test.

"Exceed" means more than: an undertaking with exactly 1,000 employees or exactly EUR 450 million net turnover is not in scope, and both values must be exceeded together. The test has no balance-sheet criterion, so the two-of-three logic of the Accounting Directive size classes no longer decides CSRD scope. The way the employee average and net turnover are measured is set out under how both CSRD thresholds are counted.

First-Wave Reporters in Financial Years 2024 to 2026

Wave 1, large public-interest entities and parents of large groups with more than 500 employees, reports for financial years starting between 1 January 2024 and 31 December 2026 (Article 5(2)(a) of Directive (EU) 2022/2464 as amended by Article 3(1)(a)(i) of Directive (EU) 2026/470). These undertakings published their first reports in 2025, on financial year 2024.

Article 3(1)(c) of Directive (EU) 2026/470 added a Member-State option to the last subparagraph of CSRD Article 5(2). For financial years starting between 1 January 2025 and 31 December 2026, Member States may exempt wave-1 undertakings or issuers "not exceeding" a net turnover of EUR 450 million "or" an average of 1,000 employees. The revised ESRS add a relief of their own: wave-one undertakings not exceeding EUR 450 million or 1,000 employees may omit all disclosure requirements of all topical standards for financial years prior to 2027 (ESRS 1 paragraph 126(a) of the 2026 set). From financial year 2027, only the new size test counts for every undertaking, former wave-1 reporters included.

Groups Based outside the Union

A group with its ultimate parent outside the Union reports under Article 40a of Directive 2013/34/EU, as amended by Article 2(13) of Directive (EU) 2026/470, when its Union net turnover exceeds EUR 450 million in each of the last two consecutive financial years and it has an EU subsidiary or branch with net turnover above EUR 200 million in the preceding financial year. The EU subsidiary or branch publishes the group report, and US and other third-country groups find the filing rules under CSRD for non-EU groups.

The first report covers the first financial year starting on or after 1 January 2028 (CSRD Article 5(2), second subparagraph) and is published within 12 months of the balance sheet date (Article 40d(1) of Directive 2013/34/EU), by 31 December 2029 for a calendar year. The standards for these reports are a Commission delegated act under Article 40b, for which Directive (EU) 2024/1306 set the date of 30 June 2026.

Smaller Undertakings and Their Customers' Data Requests

Undertakings below the size values have no CSRD reporting duty, and those with an average of not more than 1,000 employees in the preceding financial year are protected undertakings when they sit in the value chain of a reporting company (Article 19a(3) and 29a(3) of Directive 2013/34/EU as amended by Article 2(4)(b) and 2(5)(b) of Directive (EU) 2026/470). Listed SMEs left the regime entirely: Directive (EU) 2026/470 deleted Article 29c (Article 2(7)), the opt-out in Article 19a(6) and (7) (Article 2(4)(c)) and CSRD Article 5(2)(c) (Article 3(1)(a)(iii)).

A protected undertaking may decline requests for sustainability information that go beyond the voluntary standard, and an in-scope company may not require more from it. The value-chain cap list of Annex II of Delegated Regulation (EU) 2026/1560 applies from financial years beginning on or after 1 January 2027. The right to decline reaches companies through national law, and Member States must transpose Directive (EU) 2026/470 by 19 March 2027. What a customer may still ask is set out under CSRD value-chain cap on data requests.

Key Dates from 2024 to 2031

The CSRD dates run from wave 1's first financial year, starting 1 January 2024, through the new scope from financial years starting 1 January 2027 and the non-EU report from 1 January 2028, to Commission review reports due by 30 April 2029 and 30 April 2031. Every reporting date is triggered by the start of a financial year, not by a calendar year of publication. A company in the new scope with a calendar financial year reports on financial year 2027 in 2028.

The transposition dates in Table 3 bind the Member States, not companies directly: 6 July 2024 for the CSRD, 31 December 2025 for the Stop-the-clock Directive and 19 March 2027 for Directive (EU) 2026/470. The delegated regulations carry their own entry-into-force dates and apply without transposition.

The review reports are Commission duties under CSRD Article 6(1), as amended by Article 3(2) of Directive (EU) 2026/470: points (a), (b), (d) and (e) by 30 April 2029, point (c) on extending the scope by 30 April 2031, then every three years. Table 3 lists the steps in date order, and each step is dated in all CSRD dates on the timeline after the Omnibus.

What Goes into the Report

A company in scope reports in a dedicated section of its management report, applying the European Sustainability Reporting Standards (ESRS) to the sustainability matters that its double materiality assessment finds material. The ESRS come in two versions, the 2023 set and the 2026 set, each with 12 standards, and the version depends on the financial year. Table 4 lists the elements of the report and the page that explains each.

Twelve Standards in Two Versions

The ESRS consist of 12 standards in both versions: ESRS 1 and ESRS 2 as cross-cutting standards, E1 to E5 on the environment, S1 to S4 on social matters and G1 on business conduct. The first set is Delegated Regulation (EU) 2023/2772 of 31 July 2023, applying to financial years from 1 January 2024. Delegated Regulation (EU) 2025/1416, the quick fix, in force since 13 November 2025, applies to financial years from 1 January 2025. FY 2025 statements were prepared under the 2023 set (Delegated Regulation (EU) 2023/2772, as amended by Delegated Regulation (EU) 2025/1416), because the 2026 set is only available from financial years starting in 2026 (Art. 2(1) Delegated Regulation (EU) 2026/1563).

The revised (simplified) ESRS, Delegated Regulation (EU) 2026/1563 of 3 July 2026, replace Annexes I and II of the first set without repealing it, enter into force on 10 November 2026 and are mandatory for financial years beginning on or after 1 January 2027. For financial year 2026 a company may choose the 2023 set or the 2026 set and must state which version it applies (Article 2). In the 2026 set, E3 is titled "Water" instead of "Water and marine resources". According to the Commission (3 July 2026), the revised ESRS reduce mandatory datapoints by over 60 % and total datapoints by over 70 %, and are expected to cut reporting costs by more than 30 % per company.

The ESRS and the CSRD do different jobs. The CSRD creates the duty to report and decides who reports; the ESRS, adopted under Article 29b of Directive 2013/34/EU, say what to disclose and apply directly without transposition.

Which Sustainability Matters Belong in the Report

The report covers both the undertaking's impacts on sustainability matters and how sustainability matters affect its development, performance and position (Article 19a(1) of Directive 2013/34/EU), which the ESRS turn into the double materiality principle. A sustainability matter is material when it meets the impact materiality criteria, the financial materiality criteria or both (ESRS 1 paragraph 28 in the 2023 set). Directive (EU) 2026/470 kept this two-sided duty, and the 2026 set speaks of a "sustainability topic" where the 2023 set used "sustainability matter".

The severity of a negative impact is judged by its scale, scope and irremediable character, and for potential negative human-rights impacts severity takes precedence over likelihood (ESRS 1 paragraph 45 in the 2023 set, paragraph 40 in the 2026 set). Neither ESRS version requires a materiality matrix, and neither mentions one. Climate shows how the requirements differ by version: E1 has 9 disclosure requirements, E1-1 to E1-9, in the 2023 set and 11, E1-1 to E1-11, in the 2026 set, and gross GHG emissions move from E1-6 in the 2023 set to E1-8 in the 2026 set.

A Dedicated Section of the Management Report

The sustainability statement is a clearly identifiable, dedicated section of the management report (Article 19a(1) and 29a(1) second subparagraphs of Directive 2013/34/EU), not a separate sustainability report. The management report, including the statement, is published within a reasonable period not exceeding 12 months after the balance sheet date, together with the assurance opinion (Article 30(1)).

The statement also carries the disclosures under Article 8 of Regulation (EU) 2020/852 (the Taxonomy Regulation), In the 2026 set they sit inside the sustainability statement and may be placed in a separate appendix within the management report (ESRS 1 paragraph 106); in the 2023 set they belong in the environmental section (ESRS 1 paragraph 113). Those indicators are covered under EU Taxonomy reporting in the sustainability statement.

A Voluntary Standard for Undertakings up to 1,000 Employees

The voluntary standard (VS, formerly VSME) is the EU reporting standard for undertakings outside the CSRD, adopted as Annex I of Delegated Regulation (EU) 2026/1560 under Article 29ca of Directive 2013/34/EU. Article 29ca was inserted by Article 2(8) of Directive (EU) 2026/470. Its intended users are undertakings that, on their balance sheet dates, do not exceed an average of 1,000 employees during the preceding financial year (Annex I paragraph 2). The standard is voluntary: undertakings "may" report under it (Article 2(1)). It has two modules, the Basic Module with 11 disclosures, B1 to B11, and the Comprehensive Module with 9 disclosures, C1 to C9, for which the Basic Module is a prerequisite (paragraph 7).

VS reporters do not have to run a double materiality assessment (paragraph 15), and they are not obliged to seek assurance (recital 5). Delegated Regulation (EU) 2026/1560 of 3 July 2026 (OJ 21.9.2026) has been in force since 24 September 2026, and Recommendation (EU) 2025/1710 no longer produces legal effects since 24 September 2026. No official total of VS datapoints exists.

How Reporting Is Checked

Three mechanisms check CSRD reporting: an external assurance opinion at the limited level, a machine-readable format once the EU mark-up rules exist, and national supervision with national penalties. Each mechanism rests on a different provision: Article 34 of Directive 2013/34/EU for assurance, Article 29d for the format and Article 51 for penalties. All three reach companies through national law.

The Assurance Opinion at the Limited Level

Sustainability reporting is assured at the limited level only: Article 34(1) of Directive 2013/34/EU, second subparagraph, point (aa), as replaced by Article 2(12)(a) of Directive (EU) 2026/470, no longer foresees reasonable assurance, and the empowerment for reasonable-assurance standards was removed. The opinion covers four objects: compliance with the Directive and the standards adopted under Article 29b, the process used to identify the reported information, the Article 29d mark-up and the Article 8 Taxonomy disclosures. The statutory auditor of the financial statements gives the opinion by default; Member States may also allow another statutory auditor (Article 34(3)) or an independent assurance services provider (Article 34(4)).

The EU limited-assurance standard is due as a Commission delegated act by 1 July 2027 (Article 26a(3) of Directive 2006/43/EC as replaced by Article 1(3) of Directive (EU) 2026/470) and is not adopted as of 29 October 2026. Until it exists, Member States may apply national assurance standards, procedures or requirements (Article 26a(2)). ISSA 5000 is a standard of the IAASB, not an EU-adopted standard. Who may sign and what the opinion says is covered under limited assurance of CSRD reporting.

Machine-Readable Mark-Up Not Yet Required

Companies do not have to mark up their sustainability reporting until the Commission adopts mark-up rules in Delegated Regulation (EU) 2019/815 (Article 29d of Directive 2013/34/EU as replaced by Article 2(9) of Directive (EU) 2026/470), and no such rules exist as of 29 October 2026. Article 29d states that undertakings "shall not be required to mark up their sustainability reporting" until then. The management report itself, sustainability statement included, is still prepared in the single electronic reporting format that Article 29d refers to. ESMA consulted on rules for marking up sustainability information from 13 December 2024 to 31 March 2025 (ESMA32-2009130576-3024) and has published no final report.

National Penalties and Supervisory Review

Penalties for CSRD breaches are set nationally: Article 51 of Directive 2013/34/EU requires them to be effective, proportionate and dissuasive and sets no EU amount. For issuers, ESMA's Guidelines on Enforcement of Sustainability Information (GLESI, ESMA32-992851010-1815), 22 guidelines, apply to sustainability information published from 1 January 2025. Enforcement itself is carried out by national authorities: the national competent authorities for listed issuers, and national courts or registers under company law. ESMA does not fine companies.

ESMA's 2026 European Common Enforcement Priorities (13 October 2026) focus FY2026 enforcement of connected information on ESRS E1 Climate change and S1 Own workforce, because these topics are more mature; the first priority is continued progress in applying the materiality assessment. Fines and enforcers are listed under CSRD penalties and enforcement by Member State.

National Law in the Member States

Companies follow the national law that transposes the CSRD, so the date and content of each Member State's act decide when the rules bind a company there. Three transposition deadlines apply: 6 July 2024 for the CSRD (Article 5(1) of Directive (EU) 2022/2464), 31 December 2025 for the Stop-the-clock Directive (Article 3(1) of Directive (EU) 2025/794) and 19 March 2027 for Articles 1 to 3 of Directive (EU) 2026/470 (its Article 5(1)). A missing transposition of Directive (EU) 2026/470 is not late before 19 March 2027.

The delegated regulations need no transposition. Delegated Regulations (EU) 2023/2772, 2025/1416, 2026/1563 and 2026/1560 are binding in their entirety and directly applicable in every Member State, so the ESRS version and the voluntary standard are the same across the Union, while scope, dates, assurance providers and penalties come from national law.

Each country page names the national act, its instrument and its dated status, and Table 5 lists the country pages published so far. Each country's act and status is followed in the CSRD transposition tracker for the Member States.

Preparing a First Report

No EU act prescribes a CSRD project plan: the obligations a first report must meet come from Articles 19a, 29a, 29d, 30 and 34 of Directive 2013/34/EU as amended by Directive (EU) 2026/470. Those articles give the steps of a first report, listed below in the order the obligations build on each other.

1. Test both size values for the undertaking or the group (Articles 19a(1) and 29a(1)).
2. Run the double materiality assessment under the applicable ESRS version.
3. Choose and state the ESRS version for the financial year (Article 2 of Delegated Regulation (EU) 2026/1563 for financial year 2026).
4. Prepare the sustainability statement as a section of the management report and publish it within 12 months (Articles 19a, 29d and 30).
5. Obtain the limited-assurance opinion (Article 34).

No EU certification, approval list or technical standard exists for CSRD or VSME software as of 29 October 2026, so a tool's claims are checked against these articles, not against an official label.

Table 6 lists the service types that support these steps, and the steps are laid out in the step-by-step reporting plan for in-scope companies.

Where the Rules Stand on 29 October 2026

As of 29 October 2026, Directive (EU) 2026/470 has been in force since 18 March 2026 and must be transposed by 19 March 2027, the revised ESRS enter into force on 10 November 2026, and the EU limited-assurance standard is not adopted (due by 1 July 2027). The next dated steps are listed below in date order.

• 10 November 2026: Delegated Regulation (EU) 2026/1563 enters into force (Article 3).
• 1 January 2027: first financial years under the new size test; the revised ESRS become mandatory.
• 19 March 2027: transposition deadline for Articles 1 to 3 of Directive (EU) 2026/470 (Article 5(1)).
• 1 July 2027: deadline for the EU limited-assurance standard (Article 26a(3) of Directive 2006/43/EC).
• 1 January 2028: first financial years for the Article 40a report of non-EU groups.

No mark-up rules for sustainability reporting exist in Delegated Regulation (EU) 2019/815 as of 29 October 2026, and Article 29d requires no mark-up until they are adopted. The Commission's review reports under CSRD Article 6(1) follow on 30 April 2029 and 30 April 2031, the second on extending the scope.

What the CSRD Is Not

The CSRD is not an ESG rating, a label or a voluntary framework: it is a disclosure law on environmental, social and governance factors. It turns those ESG factors into sustainability matters a company must report on, and how it compares with ESG frameworks is set out under the CSRD next to other sustainability reporting frameworks.

Is There an Official Count of Reporting Companies?

No: Directive (EU) 2026/470 gives no official count of the companies in scope after the Omnibus. The figure of about 80 % that circulates belongs to the proposal, not to the adopted text. The Commission proposal of 26 February 2025 (COM(2025) 81, not adopted) would have limited mandatory reporting to large undertakings with more than 1,000 employees and either a turnover above EUR 50 million or a balance sheet above EUR 25 million, reducing the number of undertakings in scope by about 80 %.

How the Rules Relate to Global Frameworks

The ESRS apply double materiality, while the ISSB's IFRS S1 uses investor-focused materiality: information is material when it could reasonably be expected to influence the decisions of primary users (paragraph 18 of IFRS S1). The ISSB issued IFRS S1 and IFRS S2 on 26 June 2023, effective for annual reporting periods beginning on or after 1 January 2024.

The ESRS-ISSB interoperability guidance of 2 May 2024 (IFRS Foundation and EFRAG) explains that the standards were developed "to achieve a high degree of alignment of the respective standards, with a specific focus on climate-related reporting", and it states that "almost all the disclosures in ISSB Standards related to climate are included in ESRS". It refers to set 1 paragraph numbers and is not a statement of equivalence. The climate overlap is compared under interoperability of the ESRS with the ISSB frameworks.