CSRD 2026: Which companies must publish a sustainability report?

Last updated: · steward-ship

After Omnibus I (Directive (EU) 2026/470), the CSRD applies to companies with more than 1,000 employees and a net turnover above €450 million; both conditions must be met. Reporting follows the simplified ESRS adopted by Commission Delegated Regulation C(2026) 5010.

Scope criteria

CriterionThreshold
EmployeesMore than 1,000
Net turnoverMore than €450 million
ConditionBoth criteria together

What changed?

  • The Omnibus I directive was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026.
  • The planned reporting wave for listed SMEs was removed.
  • The simplified ESRS (C(2026) 5010) was adopted on 3 July 2026 and applies to financial years starting on or after 1 January 2027.

What should out-of-scope companies do?

Companies outside the mandatory scope can report with the Voluntary Standard (VS) to answer data requests from banks and large customers. Large companies may not request more than the VS from value-chain partners with up to 1,000 employees.

What does do?

determines CSRD and TSRS scope from the company profile, lists the ESRS datapoints required by the double materiality result and compiles the report from approved data.

Sources

  1. Directive (EU) 2026/470 (Omnibus I)
  2. Commission Delegated Regulation C(2026) 5010 — simplified ESRS
  3. C(2026) 5010 — Annex I (ESRS)
  4. Commission Delegated Regulation C(2026) 5011 — Voluntary Standard
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ESRS 2026 · TSRS · Voluntary Standard (VS)