Does CSRD Still Apply to Us After the Omnibus? A Scope and Timing Checklist for US Groups

Short answer: from financial years starting on or after 1 January 2027, CSRD reporting applies only to undertakings, or groups on a consolidated basis, that exceed both EUR 450 million of net turnover and an average of 1,000 employees. The 2025 stop-the-clock directive only moved dates; it was Omnibus I (Directive (EU) 2026/470) that redrew the scope, and Member States must transpose it by 19 March 2027. If your EU entity reported for FY2024 under the old 500-employee test, you may be out of scope from FY2027, or even earlier if your Member State uses an optional exemption for FY2025 and FY2026.

Two laws, two different effects: timing versus scope

Most of the confusion comes from treating the 2025 and 2026 changes as one "postponement". The texts indexed in the CSRD and ESRS knowledge base show two separate moves:

• Directive (EU) 2025/794 ("stop-the-clock"), adopted on 14 April 2025, changed only the introductory wording of Article 5(2) of the CSRD. The second wave moved to "financial years starting on or after 1 January 2027" and the third wave to "on or after 1 January 2028". Its recitals explain that undertakings due to report for financial years beginning in 2025 and 2026 should be postponed by two years. It did not touch the thresholds.
• Directive (EU) 2026/470 (Omnibus I), adopted on 24 February 2026 and published in the Official Journal on 26 February 2026, rewrote who is in scope. Its recital 7 limits the obligation to undertakings "with a net turnover exceeding EUR 450 000 000 and an average of more than 1 000 employees during the financial year", and the same logic applies to groups and issuers. It entered into force on the twentieth day after publication, which is why the consolidated texts in the base are dated 18 March 2026.

So the right question is not "was CSRD postponed?" but "which version of Article 5(2) applies to my entity for this financial year?"

The scope test, period by period

The consolidated CSRD (version of 18 March 2026) now reads in two time blocks. For US groups, the relevant entities are usually an EU subsidiary that prepares a management report, an EU sub-holding that consolidates EU operations, or the group itself if it has securities admitted to trading on an EU regulated market (the "issuers" covered by the third subparagraph of Article 5(2)).

Both conditions in the 2027 test are cumulative. A group with EUR 300 million of turnover and 600 employees fails both, and a group with EUR 2 billion of turnover but 900 employees fails the employee limb. Either way it is outside Articles 19a and 29a of the Accounting Directive from FY2027.

A five-step checklist for a group that reported for FY2024

1. Identify the reporting entity. Is it an EU subsidiary, an EU parent of an EU sub-group, or an issuer with securities on an EU regulated market? The test is applied at that level, on a consolidated basis where it is a parent.
2. Confirm your FY2024 basis. If you reported for FY2024, you were almost certainly a "wave-one" undertaking under the 500-employee PIE test, which now only runs to financial years starting by 31 December 2026.
3. Apply the 2027 test to both numbers. Use net turnover and the average number of employees during the financial year, measured on the balance sheet date. Both must exceed the limits.
4. Check the national transposition. Omnibus I Article 5 requires Member States to bring the CSRD changes (its Articles 1 to 3) into force by 19 March 2027. Your EU entity's obligations flow from the law of its Member State.
5. Check FY2025 and FY2026 separately. If your Member State used the optional exemption, a wave-one entity under the new thresholds might have nothing to file for those years. If not, the ESRS set 1 rules (with the 2025 quick fix) still apply to those years.

If you stay in scope: which standards apply when

Staying in scope does not mean reporting the same way. Three standards regimes overlap between 2024 and 2027:

• FY2024 to FY2026: ESRS set 1 (Delegated Regulation (EU) 2023/2772). For financial years beginning on or after 1 January 2025, it is read with Delegated Regulation (EU) 2025/1416 (the "quick fix"), which extended phase-in reliefs to wave-one undertakings, including those above 750 employees, for topics such as ESRS E4, S2, S3 and S4.
• FY2026 only: a choice. Article 2 of Delegated Regulation (EU) 2026/1563 lets undertakings use either ESRS set 1 as amended by the quick fix, or the new simplified ESRS, or set 1 with eight listed reliefs from the new text. You must state which version you used.
• FY2027 onward: the simplified ESRS of Delegated Regulation (EU) 2026/1563, which enters into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027.

The simplified ESRS also include phase-ins for wave-one undertakings that remain in scope. For example, paragraph 125 of the new ESRS 1 lets them omit ESRS E4, S2, S3 and S4 for financial years before 2027, and quantitative anticipated financial effects for financial years before 2030 (with listed exceptions in E1-11).

If you drop out: what still matters

Falling outside Articles 19a and 29a does not make sustainability data disappear from your EU business relationships. Three points from the base are worth keeping in mind:

• Value-chain requests are capped. If your EU entity averages no more than 1,000 employees in the preceding financial year and supplies an in-scope company, it is a "protected undertaking" and may decline requests beyond the voluntary standard. Article 3 of Delegated Regulation (EU) 2026/1560, which sets that cap, applies from financial years beginning on or after 1 January 2027.
• A voluntary standard exists. Delegated Regulation (EU) 2026/1560 sets a voluntary sustainability reporting standard for undertakings not subject to mandatory reporting, based on Commission Recommendation (EU) 2025/1710.
• Non-EU parent rules come later. From financial years starting on or after 1 January 2028, Article 40a can require an EU subsidiary or branch to publish a report at the level of the non-EU group. The thresholds are EUR 450 million of EU turnover for the group and EUR 200 million for the subsidiary or branch.

Common mistakes when reading the new rules

• Treating stop-the-clock as a scope change. It moved dates for waves two and three only. It did not release a wave-one company from FY2024 or FY2025 reporting.
• Reading "or" for "and". The 2027 test needs turnover above EUR 450 million and more than 1,000 employees. The optional FY2025-2026 exemption is drafted the other way round: it covers entities that do not exceed either limit.
• Assuming the directive applies directly. Omnibus I is a directive. Its CSRD changes reach companies through national transposition, due by 19 March 2027. The ESRS, by contrast, are delegated regulations that apply directly.
• Forgetting the US framing. The base covers EU law only. It says nothing about SEC or state climate disclosure rules, so do not read ESRS answers as a statement on US obligations.

To test a specific fact pattern, you can put your question to the base in plain words, for example: "Our listed group has an average of 600 employees and EUR 300 million turnover; we reported under CSRD for FY2024. Do we still have to report for the financial year starting 1 January 2027?" Each answer cites the article it relies on, so your counsel can check it against the consolidated CSRD on EUR-Lex and the Omnibus I directive.

This article explains the EU rules as written in the official texts indexed on 5 October 2026. It is not legal advice. National transposition choices and your group's figures decide the outcome, so confirm them with your advisers.