The Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464) requires detailed sustainability reporting under the ESRS standards, on a double-materiality basis. Who has to do it is changing, so here is the current picture.
The original scope (phased in)
A company was in scope if it was a large undertaking meeting at least two of three criteria: 250+ employees, EUR 50M+ net turnover, EUR 25M+ balance sheet - plus large listed companies and, later, listed SMEs. Reporting was phased across waves from 2024 to 2028.
The Omnibus shift (this is the part that changed)
In February 2025 the Commission proposed an Omnibus simplification package that significantly narrows CSRD:
- A "stop-the-clock" delay postponed reporting for companies not yet in their first wave by two years.
- A proposed substantive change would raise the main threshold to around 1,000 employees, taking a large share of previously in-scope companies out.
As of mid-2026 the threshold change is still being finalised in EU negotiation. Treat the exact scope as moving and confirm the current status before acting.
What to do now
- If you were already reporting in wave 1 (large public-interest entities), you continue.
- Everyone else: track the final Omnibus outcome rather than building a full program against the original thresholds.
-> Use the QuickScan to see which EU regulations (CSRD, NIS2, CBAM, GDPR, PPWR, AI Act) currently apply to your business.
Source
Directive (EU) 2022/2464 (CSRD). The Omnibus package amends this; verify the latest consolidated text on EUR-Lex.
Last verified: 21 June 2026. CSRD scope is changing rapidly under the Omnibus package; confirm current status.