CSRD Thresholds after the Omnibus: More than 1,000 Employees and EUR 450 Million Turnover, and How to Count Them

The Corporate Sustainability Reporting Directive (CSRD) is Directive (EU) 2022/2464 of 14 December 2022, in force since 5 January 2023, and Directive (EU) 2026/470 of 24 February 2026, in force since 18 March 2026, replaced its size test. Both acts are directives: they bind the Member States, and a company follows the national law of its Member State, which until transposition still reflects the earlier text. The two thresholds decide who reports under the Corporate Sustainability Reporting Directive (CSRD) together with the other scope conditions.

The table summarises the threshold test as of 29 October 2026; the sections below cover the wording, the counting rules, six worked examples, the first financial year and the values that were replaced.

What Are the Two Thresholds Now?

The CSRD has had two thresholds since Directive (EU) 2026/470 entered into force on 18 March 2026: a net turnover of more than EUR 450 million and an average of more than 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, covers "undertakings which, on their balance sheet dates, exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year". Member States must transpose it by 19 March 2027 (Article 5(1)).

The two thresholds are one condition of the scope test, not the whole test. The other conditions are the legal form of the undertaking, its status as a bank or insurer, and its status as an issuer whose securities are admitted to trading on an EU regulated market.

Why Both Criteria Must Be Exceeded

A company is in scope only when it exceeds both values: a high turnover with 1,000 employees or fewer, or a large workforce with a turnover of EUR 450 million or less, keeps it out. The two criteria are cumulative because Article 19a(1) joins them with "and", and Article 29a(1) does the same for groups. No third criterion exists, and the balance sheet total plays no part in the test. Before Directive (EU) 2026/470, a large undertaking was one that exceeded two of three criteria, one of them the balance sheet total.

What "More Than" Means at Exactly 1,000 Employees or EUR 450 Million

"Exceed" means more than, so a company with exactly 1,000 average employees or exactly EUR 450 million net turnover does not meet the test. An average of 1,001 employees exceeds the employee value, and a net turnover of EUR 450,000,001 exceeds the turnover value.

Individual Undertaking and Group: Two Tests on Different Figures

The same two values are applied twice in Directive 2013/34/EU: Article 19a(1) tests each undertaking on its own figures, and Article 29a(1) tests the group of a parent undertaking on consolidated figures. Both tests sit inside the scope test that also asks about legal form and issuer status.

The table compares the two tests side by side.

The Individual Test for a Single Undertaking

Under Article 19a(1) of Directive 2013/34/EU as replaced by Article 2(4)(a) of Directive (EU) 2026/470, an undertaking that exceeds both values on its balance sheet date includes sustainability information in a dedicated section of its management report. Issuers within the meaning of Article 2(1)(d) of Directive 2004/109/EC apply the same EUR 450 million and 1,000-employee test (Article 5(2), third subparagraph of Directive (EU) 2022/2464 as amended by Article 3(1)(b) of Directive (EU) 2026/470). Banks and insurers are in scope regardless of their legal form once they exceed both values (Article 1(3) of Directive 2013/34/EU as amended by Article 2(1)(a) of Directive (EU) 2026/470).

The Consolidated Test for a Parent Undertaking

Under Article 29a(1), as replaced by Article 2(5)(a) of Directive (EU) 2026/470, a parent undertaking reports for its group when the group exceeds EUR 450 million net turnover and 1,000 employees on a consolidated basis. The parent's own size is irrelevant: a holding company with a small staff of its own reports for the group as soon as the consolidated figures exceed both values.

Subsidiaries included in the parent's consolidated sustainability report may be exempt from reporting on their own. Since Directive (EU) 2026/470 replaced Article 19a(10) and Article 29a(9), this exemption is also open to public-interest entities, such as listed large undertakings, which the earlier text excluded. The conditions are set out under consolidated reporting and the subsidiary exemption.

How Are Employees and Net Turnover Counted?

Directive (EU) 2026/470 does not define the two figures itself: recital 7 refers to net turnover and employees "as defined in the national measures transposing Directive 2013/34/EU", so the counting follows the Accounting Directive and the company's national law. The consolidated text of Directive 2013/34/EU on EUR-Lex, dated 18 March 2026, already includes the amendments made by Directive (EU) 2026/470.

Average Number of Employees

The employee figure is an average over the financial year, not a headcount taken on a single day. Union law does not regulate how the average is calculated. According to FAQ 3 of Commission Notice C/2024/6792, published in the Official Journal on 13 November 2024, national rules apply, and where none exist the annual work unit method of Article 5 of the Annex to Commission Recommendation 2003/361/EC of 6 May 2003 (OJ L 124, 20.5.2003, p. 36) may be used as guidance. The notice predates Directive (EU) 2026/470, so its answers on listed SMEs and on the earlier thresholds are not current law.

In practice, a company takes the method that its national accounting law prescribes, applies it to the whole financial year and records the method next to the figure. A parent undertaking applies the same approach to the average number of employees of its group, because Article 29a(1) asks for the average "on a consolidated basis".

Net Turnover under Article 2(5) of the Accounting Directive

Net turnover is the amount derived from the sale of products and the provision of services after deducting sales rebates, value added tax and other taxes directly linked to turnover (Article 2(5) of Directive 2013/34/EU). The figure compared with EUR 450 million is therefore net of VAT and rebates, not gross sales.

Banks and insurers use sector definitions. For credit institutions, net turnover follows Article 43(2)(c) of Directive 86/635/EEC; for insurance undertakings, it follows Article 35 and point 2 of Article 66 of Directive 91/674/EEC. For the Article 40a test of third-country undertakings, net turnover means revenue under the applicable financial reporting framework. The sector rules are explained under net turnover of banks and insurers under the CSRD.

The Balance Sheet Date and the Financial-Year Average

Article 19a(1) asks whether the undertaking exceeds the values "on their balance sheet dates", with employees averaged "during the financial year". Article 29a(1) applies the same "during the financial year" wording to the group, which exceeds the values "on a consolidated basis".

Article 40a(1) states its own period: the Union net turnover test for third-country undertakings applies in "each of the last two consecutive financial years". For the size categories of the Accounting Directive, FAQ 1 and 2 of the Commission's 2024 notice left the timing rules to the national measures transposing the Directive. The national law of the company's Member State therefore governs how the figures are taken.

Worked Examples: Which Companies Exceed Both Thresholds

Six cases show how the test works: only a company or group above both EUR 450 million net turnover and 1,000 average employees is in scope.

The figures are calculated illustrations, not statements about any company. The result in a given Member State depends on how its national law transposes Articles 19a(1) and 29a(1).

From Which Financial Year Do the Thresholds Apply?

The new thresholds decide reporting for financial years starting on or after 1 January 2027, so the first reports under them are published in 2028 (Article 5(2), first subparagraph, point (b) of Directive (EU) 2022/2464 as amended). Directive (EU) 2025/794 set this date by moving the original start, financial years from 1 January 2025, back by two years, and Directive (EU) 2026/470 replaced the criteria with the EUR 450 million and 1,000-employee test (Article 3(1)(a)(ii)). Each wave's dates are set out under the first financial year on the CSRD timeline.

The trigger is the start date of the financial year. For a company whose financial year starts on 1 July (30 June year-end), the year starting on 1 July 2026 still falls before the new test, and the first financial year under it is the one starting on 1 July 2027, reported after its balance sheet date of 30 June 2028 (calculated).

Former Wave 1 Companies below the New Values

Wave 1 (large public-interest entities and public-interest parents of large groups, each with more than 500 employees) reports for financial years starting between 1 January 2024 and 31 December 2026 only, and from financial years starting on or after 1 January 2027 such a company stays in scope only if it exceeds both new values (Article 5(2)(a) of Directive (EU) 2022/2464 as amended by Article 3(1)(a)(i) of Directive (EU) 2026/470). The last subparagraph of Article 5(2), added by Article 3(1)(c) of Directive (EU) 2026/470, lets Member States exempt wave 1 undertakings and issuers that do not exceed a net turnover of EUR 450 million or an average of 1,000 employees, on a consolidated basis where applicable, for financial years starting from 1 January 2025 to 31 December 2026. Article 40a obligations are excepted.

Whether a wave 1 company benefits depends on its Member State. As of 29 October 2026, Austria has used the option: under § 908 Abs. 2a UGB (the Austrian Commercial Code), undertakings with up to EUR 450 million turnover or not more than 1,000 employees on average are not obliged to report for the individual report and may apply the rules voluntarily; the same applies to groups. The relief is one of the changes listed under what Omnibus I changed for wave 1.

Earlier Thresholds and Why They No Longer Apply

Before Directive (EU) 2026/470, the CSRD covered every large undertaking, meaning one that exceeded two of three size criteria built around 250 employees, plus listed SMEs, and these values no longer decide CSRD scope. The table lists each regime with the instrument that set it.

The NFRD row still describes national law where a Member State has not transposed the CSRD: as of 29 October 2026 Germany has not transposed it and still applies the CSR-RUG, its transposition of Directive 2014/95/EU.

Delegated Directive (EU) 2023/2775 of 17 October 2023 raised the 2013 values by 25 % for inflation (cumulated inflation from 1 January 2013 to 31 March 2023: 24.3 % in the euro area, 27.2 % in the Union) for financial years beginning on or after 1 January 2024. Those values still define the size classes of the Accounting Directive (micro EUR 450,000 balance sheet, EUR 900,000 net turnover, 10 employees; small EUR 5 million, EUR 10 million, 50; medium EUR 25 million, EUR 50 million, 250), not CSRD scope.

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 %. After a political agreement in December 2025, the act signed on 24 February 2026 set EUR 450 million and 1,000 employees instead. The dates had moved first, through the earlier postponement by the Stop-the-clock Directive (EU) 2025/794 of 14 April 2025.

Where the Same Values Appear Elsewhere in the Accounting Directive

The two values recur, together or alone, in other provisions of the amended Accounting Directive and the CSRD, each with its own basis.

• Banks, insurers and issuers: both values, whatever the legal form; see CSRD for banks and insurers.
• Key intangible resources: both values decide who reports on them (Article 19(1), fourth subparagraph, as replaced by Article 2(3) of Directive (EU) 2026/470); see Articles 19a, 29a and 40a explained.
• Non-EU groups: EUR 450 million Union net turnover only, in each of the last two consecutive financial years, plus an EU subsidiary or branch above EUR 200 million, from financial years starting on or after 1 January 2028 (Article 40a(1) as amended by Article 2(13)); see non-EU companies and the Article 40a test.
• Protected undertakings: 1,000 employees only, averaged during the preceding financial year (Article 19a(3) as amended); see the value-chain cap for undertakings up to 1,000 employees.
• Listed SMEs: removed from mandatory scope by Article 3(1)(a)(iii) of Directive (EU) 2026/470; see SMEs and listed SMEs under the CSRD.

Funds (UCITS and AIFs) and the European Financial Stability Facility are excluded from Articles 19a, 29a and 29d whatever their size (Article 1(4) as replaced by Article 2(1)(b)).

How to Test Your Company against Both Thresholds

Run the test in six steps, in this order, and keep the figures, the counting method and the article behind each step on file.

1. Confirm the legal form, bank or insurer status, or issuer status.
2. Take net turnover under Article 2(5) of Directive 2013/34/EU.
3. Calculate average employees by the national method.
4. Apply both values to the undertaking's own figures, then to the consolidated figures if it is a parent undertaking.
5. Fix the first financial year: on or after 1 January 2027, or for wave 1 the years 2024 to 2026 with the national option.
6. Check the national law in the CSRD transposition tracker for the new thresholds and run the CSRD scope check.

Once both thresholds are exceeded, the reporting steps are set out in our CSRD compliance plan.

How the Thresholds Can Still Change

The values can move in two ways: the Commission reviews them for inflation at least every five years and may adjust them by delegated act, and each Member State writes them into its national law by 19 March 2027. The review covers Articles 19(1) fourth subparagraph, 19a(1), 29a(1) and 40a(1) (Article 3(13)(b) and (c) of Directive 2013/34/EU as replaced by Article 2(2) of Directive (EU) 2026/470), under a delegation for an indeterminate period from 18 March 2026 (Article 49(2a)). The Commission's CSRD page summarises the rules.

EUR-Lex records national measures notified for Directive (EU) 2026/470 by four Member States (Belgium, Finland, Croatia and Poland) as of 29 October 2026; a recorded measure is not a confirmation of full transposition. The dated status of each Member State is in the CSRD transposition tracker for the new thresholds.

Threshold Questions

Five questions recur about the CSRD thresholds.

Is a company with 250 employees still covered?

No, not on that basis: the 250-employee large-undertaking test stopped deciding CSRD scope when Directive (EU) 2026/470 replaced Article 19a(1), and from financial years starting on or after 1 January 2027 a company needs more than 1,000 employees and more than EUR 450 million net turnover. Until transposition, national law, which may still reflect the earlier test, sets a company's duties.

Does a company with exactly 1,000 employees have to report?

No: from financial years starting on or after 1 January 2027 the test requires more than 1,000 average employees, so exactly 1,000 does not exceed it, whatever the turnover.

Is the balance sheet total still part of the test?

No: Articles 19a(1) and 29a(1) as replaced by Directive (EU) 2026/470 use only net turnover and average employees.

Are part-time employees counted in full?

That depends on the national counting rules: Union law does not regulate the calculation, and where national rules are silent the annual work unit method of Article 5 of the Annex to Recommendation 2003/361/EC may serve as guidance. That method, written for the SME definition, counts part-time and seasonal work as fractions of a unit.

What can companies below the thresholds still be asked for?

A company with not more than an average of 1,000 employees in the preceding financial year is a protected undertaking when it sits in the value chain of a reporting company (Article 19a(3) of Directive 2013/34/EU as amended): the reporting company may not require more from it than the Annex II datapoints of Delegated Regulation (EU) 2026/1560, in force since 24 September 2026, which apply to "financial years beginning on or after 1 January 2027" (Article 4). It may also report voluntarily under Annex I of that act, the voluntary standard for companies below the thresholds (VS, formerly VSME).