CSRD Scope Check: Does Your Company Have to Report after the Omnibus, and from Which Year?

The result is indicative: it applies the EU text and never decides on a named company.

The Corporate Sustainability Reporting Directive (CSRD) is Directive (EU) 2022/2464. A directive binds the Member States, and a company follows its national law. The check is one part of the CSRD explained after the Omnibus.

Have ready the legal form, net turnover, average employees, group structure and the start of the financial year. The answers stay in the browser: nothing is stored or sent.

How the Check Works: Seven Questions in Legal Order

The check moves from who the company is to how large it is, then to when the duty starts and whether an exemption or the non-EU route applies, and it stops at the first question that decides the result. Each question shows its article from Directive (EU) 2026/470.

Question 1: Legal Form, Banks, Insurers and Listed Issuers

The first question asks whether the company has a legal form listed in Annex I or Annex II of Directive 2013/34/EU, is a credit institution or insurance undertaking of any legal form, or is an issuer on an EU regulated market. Banks and insurers are covered regardless of legal form once they exceed both values (Article 1(3) as replaced by Article 2(1)(a) of Directive (EU) 2026/470). UCITS, AIFs and the European Financial Stability Facility are excluded (Article 1(4) as replaced by Article 2(1)(b)), and the check ends for them.

Issuers under Article 2(1)(d) of Directive 2004/109/EC face the same size test (Article 5(2), third subparagraph, point (b) of Directive (EU) 2022/2464 as amended). A non-EU undertaking without a listing goes to question 6. The question is one of the legal form and the other gates of the scope test.

Questions 2 and 3: The Individual and the Consolidated Size Test

Question 2 applies Article 19a(1) of Directive 2013/34/EU as replaced by Article 2(4)(a) of Directive (EU) 2026/470: the company is in scope when, on its balance sheet date, it exceeds a net turnover of EUR 450 million and an average of 1,000 employees during the financial year. Both values are cumulative, "exceed" means more than, and the balance sheet total plays no role.

Question 3 applies Article 29a(1), as replaced by Article 2(5)(a), to a parent on consolidated figures; the parent's own size is irrelevant. A financial holding parent with independent subsidiaries may choose not to report on a consolidated basis (Article 29a(7a)), and subsidiaries in scope in their own right still report.

The figures follow national law (recital 7), and employees are averaged by national rules. The CSRD thresholds and how the size test counts them have their own page.

Question 4: The First Financial Year under the New Test

A company that passes question 2 or 3 reports for financial years starting on or after 1 January 2027, with the first report published in 2028 (Article 5(2), first subparagraph, point (b) of Directive (EU) 2022/2464 as amended).

Former wave 1 reported for financial years starting between 1 January 2024 and 31 December 2026 only. For those starting between 1 January 2025 and 31 December 2026, Member States may exempt undertakings or issuers not exceeding EUR 450 million net turnover or an average of 1,000 employees (Article 5(2), final subparagraph; recital 31). A former wave 1 company that does not exceed both new values is out from financial years starting on or after 1 January 2027.

Question 5: Exemption through a Parent's Consolidated Report

A subsidiary that is in scope on its own figures is exempt when it is included in its parent's consolidated management report and meets the conditions of Article 19a(9) of Directive 2013/34/EU (Article 29a(8) for a subsidiary that is itself a parent). Its report names the parent and its registered office, links the consolidated report and the assurance opinion, and states the exemption. Public-interest entities may also use it since Article 19a(10) and Article 29a(9) were replaced.

A third-country parent's report under the ESRS or equivalent standards can serve. Article 48i applies until 6 January 2030. See consolidated reporting and the subsidiary exemption.

Question 6: Non-EU Groups with EU Turnover

A non-EU undertaking enters the Article 40a route when its net turnover in the Union 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 (Article 40a(1) as amended by Article 2(13)). A branch counts only where no qualifying subsidiary exists. The first financial year starts on or after 1 January 2028, with the report within 12 months of the balance sheet date (Article 40d(1)).

A financial holding option exists, and the Article 40a report does not exempt an EU subsidiary from its own Article 19a or 29a duty.

Question 7: Below Both Thresholds

A company that fails every route is out of mandatory CSRD scope, and if it had an average of not more than 1,000 employees in the preceding financial year it is a protected undertaking in the value chain of reporting companies (Articles 19a(3) and 29a(3) as amended). Listed SMEs are no longer a separate route.

A protected undertaking may decline requests beyond the voluntary standard (VS, formerly VSME), with the Annex II datapoints of Delegated Regulation (EU) 2026/1560 as the cap from financial years beginning on or after 1 January 2027. Reporting companies may rely on a self-declaration. The value-chain cap below both thresholds has its own page.

What the Result Screen Shows

The status line reads: EU rules in force since 18 March 2026; national transposition due by 19 March 2027; your Member State's law and counting rules apply. A calculated illustration: 1,001 average employees and EUR 451 million net turnover give outcome A.

Once the CSRD applies, the reporting steps are set out in CSRD compliance after the Omnibus.

What the Check Cannot Decide for You

The check applies the EU text, so it cannot replace the national law that binds the company, the national method of counting employees, or a decision about a named company. The result stays indicative and is not legal or audit advice.

The thresholds can still change: the Commission reviews them at least every five years and may adjust the values of Articles 19a(1), 29a(1) and 40a(1) by delegated act (Article 3(13)(b) and (c) as replaced by Article 2(2) of Directive (EU) 2026/470; delegation from 18 March 2026, Article 49(2a)). The Commission's corporate sustainability reporting page tracks the EU rules; the CSRD transposition tracker to decide the national position tracks the national ones.

From the Result to the Next Step

Each result points to one page that explains the rule behind it in full.

• Reporting plan once in scope: CSRD compliance after the Omnibus.
• Dates per wave: first financial years on the CSRD timeline.
• The amending act: what Omnibus I changed in the scope.
• Listed SMEs and value-chain requests: SMEs and the CSRD after the Omnibus.
• The voluntary route below the values: voluntary standard (VS, formerly VSME).
• The article texts behind each question: Articles 19a, 29a and 40a explained.

Scope Check Questions

Four questions come up about the check.

Is the result of the check legally binding?

No: the check gives an indicative result based on the EU text, and the company's duty follows from the national law of its Member State.

Does the check still use the 250-employee test?

No: before Directive (EU) 2026/470, Article 19a(1) covered large undertakings, which exceed two of three criteria including 250 employees (Article 3(4) as amended by Delegated Directive (EU) 2023/2775); the check uses more than EUR 450 million net turnover and an average of more than 1,000 employees.

What if a company has exactly 1,000 employees?

It is not in scope on the size test, because the test requires more than 1,000 average employees; on the same figure it is a protected undertaking if exactly 1,000 was also its average in the preceding financial year.

Can the check be used for a bank or an insurer?

Yes: credit institutions and insurance undertakings of any legal form face the same EUR 450 million and 1,000-employee test under Article 1(3) of Directive 2013/34/EU as replaced by Article 2(1)(a) of Directive (EU) 2026/470.