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CSRD scope after Omnibus I: who still has to report from 2027

Omnibus I sharply narrowed the list of undertakings that must publish a sustainability statement. This page explains the new thresholds and what happens to companies that already reported.

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The new thresholds from financial year 2027

For financial years starting on or after 1 January 2027, the reporting requirements apply to undertakings which, on their balance sheet dates, exceed a net turnover of EUR 450 000 000 and an average of 1 000 employees during the financial year. The same test applies to parent undertakings of a group, measured on a consolidated basis, and to issuers whose securities are admitted to trading on a regulated market.

The reference to listed small and medium-sized undertakings has been removed. The reduced scope also applies to credit institutions and insurance undertakings, regardless of their legal form.

What happens to first-wave reporters

The first set of undertakings, large public-interest entities with more than 500 employees, now reports under that criterion only for financial years starting between 1 January 2024 and 31 December 2026. Those that do not meet the new thresholds fall outside the scope from financial years starting on or after 1 January 2027.

Member States may also exempt them earlier: undertakings or issuers that do not exceed a net turnover of EUR 450 000 000 or an average of 1 000 employees may be exempted for financial years starting between 1 January 2025 and 31 December 2026. Whether your country uses that option depends on its national transposition.

Below the thresholds: voluntary reporting

Undertakings below the thresholds remain free to report voluntarily. Omnibus I requires the Commission to adopt a sustainability reporting standard for voluntary use, now set out in Delegated Regulation (EU) 2026/1560, and undertakings using it may also rely on practical guidance provided by EFRAG.

The Omnibus also asks the Commission to assess later whether the scope should be extended, in particular to large undertakings below the EUR 450 000 000 turnover and 1 000 employee thresholds and to third-country undertakings operating in the internal market without an EU subsidiary or branch.

Frequently asked questions

Do both thresholds have to be exceeded?

Yes. The texts require an undertaking to exceed a net turnover of EUR 450 000 000 and an average of 1 000 employees. Exceeding only one of the two is not enough to be in scope from 2027.

By when must Member States transpose Omnibus I?

Member States must bring into force the measures needed to comply with the CSRD-related articles of Directive (EU) 2026/470 by 19 March 2027.

Does the reduced scope also cover the report on key intangible resources?

Yes. The requirement to report on key intangible resources and their role in the business model now only applies to undertakings with a net turnover above EUR 450 000 000 and more than 1 000 employees on average.

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MCP URL
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Claude Code, Cursor and other clients
Claude Code
claude mcp add --transport http kopik-eu-csrd-esrs-reporting "https://kopik.io/api/mcp?base=eu-csrd-esrs-reporting" --header "Authorization: Bearer kpk_…"
JSON config (mcpServers)
{
  "mcpServers": {
    "kopik-eu-csrd-esrs-reporting": {
      "url": "https://kopik.io/api/mcp?base=eu-csrd-esrs-reporting",
      "headers": {
        "Authorization": "Bearer kpk_…"
      }
    }
  }
}

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