Directive (EU) 2026/470 narrows CSRD to undertakings exceeding both an average of more than 1,000 employees and more than EUR 450 million net turnover. Both tests must be met, cumulatively. The change applies to financial years beginning on or after 1 January 2027, with first reports in 2028. Roughly 90 per cent of previously in-scope undertakings fall out.
The Omnibus is enacted law, not a proposal. Directive (EU) 2026/470 of 24 February 2026 was published in the Official Journal on 26 February 2026 and entered into force on the twentieth day following publication, 18 March 2026. Member States must transpose it by 19 March 2027. Any summary describing the package as proposed is now out of date.
The scope test
| Test | Threshold | Applies |
|---|---|---|
| Employees | More than 1,000 on average during the financial year | Cumulatively with the turnover test |
| Net turnover | More than EUR 450 million | Cumulatively with the employee test |
The word doing most of the work is “and”. The two thresholds are cumulative, not alternative. An undertaking above the employee threshold but below the turnover threshold is outside scope, and so is one above the turnover threshold but below the employee threshold. Only an undertaking clearing both is caught. Reading the test as an either/or materially overstates the population still reporting.
Timing
The scope change applies to financial years beginning on or after 1 January 2027, with the first reports appearing in 2028. That is the date for EU undertakings. A different and later timetable applies to non-EU parent undertakings caught by the third-country rule, and the two should not be conflated.
What falls away does not fall silent
Roughly 90 per cent of previously in-scope undertakings leave mandatory CSRD reporting. That does not mean they stop being asked for sustainability data. A company outside statutory scope still faces buyer, lender and investor requirements, which are contractual rather than legal, and those sit outside the protections built into the reporting framework.
Sources: Directive (EU) 2026/470, Council of the EU press release, 24 February 2026
Falling out of scope changes the obligation but rarely the workload. ESG solutions covers scope assessment and reporting readiness, and the ESG guide sets out the disclosure structure that buyer questionnaires continue to draw from.