Does CSRD still apply to your company?
Yes — CSRD still applies, but to far fewer companies than first written. Since Directive (EU) 2026/470 entered into force on 18 March 2026, mandatory sustainability reporting narrows to undertakings with more than 1,000 average employees and more than EUR 450 million net turnover — both tests at once. Whether CSRD applies to your company now comes down to a scope check you can run in about 60 seconds. Here it is, with every date and threshold sourced to the directive.
The Omnibus rewrote the scope.
Two EU acts moved the goalposts between 2025 and 2026. One bought time; the other decided who still has to report at all.
Directive (EU) 2026/470 — published in the Official Journal on 26 February 2026, in force since 18 March 2026 — limits mandatory CSRD to undertakings above both lines. The criteria are cumulative: missing either one takes you out.
Before the scope was redrawn, the stop-the-clock Directive (EU) 2025/794 of 14 April 2025 had already postponed wave-2 and wave-3 reporting by two years. For companies still in scope, the first wave-2 report now lands in 2028, on FY2027.
The former wave 3 — listed SMEs — is removed from mandatory scope entirely. The voluntary VSME standard takes its place as the reporting language for smaller companies.
The result: the post-Omnibus question is rarely about deadlines any more. It is about whether you are still in scope at all.
Check your status in 60 seconds.
- Count average employees. Did the undertaking average more than 1,000 employees over the financial year? That is the first of the two cumulative tests under Directive (EU) 2026/470.
- Check net turnover. Is it above EUR 450 million? Both criteria must be met together — a 5,000-person company below the turnover line is out, and so is a high-turnover company with 800 employees.
- Listed SME? You are no longer in mandatory scope, whatever your listing. The former wave 3 was removed outright.
- Non-EU parent? Non-EU groups come into scope through net turnover generated in the EU — the group threshold was raised to EUR 450 million.
- Above both lines? Plan for a first mandatory report in 2028 on FY2027, prepared under the revised ESRS. For calendar-year companies the FY2027 data year begins on 1 January 2027.
- Below either line? No mandatory CSRD report — but expect VSME-shaped data requests from banks and large customers instead of silence.
Who still reports, and when.
| Who | Before the Omnibus | Where you stand now |
|---|---|---|
| Wave 1 — large listed companies and PIEs with more than 500 employees (old rules) | First movers: reported FY2024 and FY2025 under the existing ESRS | Stay in only above 1,000 employees and EUR 450m net turnover; companies below the new lines fall out as Member-State transposition lands |
| Wave 2 — other large undertakings | Next in line, until the stop-the-clock directive added two years | First report in 2028 on FY2027 — and only if both new thresholds are met; below them, out entirely |
| Wave 3 — listed SMEs | Scheduled to follow wave 2 | Removed from mandatory scope; VSME is the voluntary route |
| Non-EU groups | Caught by a lower EU net-turnover test | In scope where EU net turnover exceeds EUR 450 million |
Thresholds and dates per Directive (EU) 2026/470 (OJ 26 February 2026, in force 18 March 2026) and Directive (EU) 2025/794 (14 April 2025). National positions can differ until transposition, due by 19 March 2027.
Directives bind Member States, not companies directly. Until your Member State transposes Directive (EU) 2026/470 — the deadline is 19 March 2027 — your formal position under national law may still reflect the old thresholds. Wave-1 companies below the new lines fall out of scope as transposition lands, not before. Check the national statute, not just the EU text, before you switch any reporting off.
In scope or out — what it means in practice.
If both tests point in, your first mandatory report arrives in 2028 on FY2027 — and it will be written under the revised ESRS. The Commission adopted the delegated act on the simplified standards on 3 July 2026, amending Delegated Regulation (EU) 2023/2772; as of October 2026 it sits in the Parliament and Council scrutiny period, applies mandatorily from financial years beginning 1 January 2027, and allows voluntary early application for FY2026 if it is published in the Official Journal in time. The gateway exercise has not changed: a double materiality assessment decides which topics your report must cover at all.
If either test points out, no law obliges you to publish a CSRD report. What replaces the obligation is the value chain: banks and large customers still need ESG data from you, and the EU's designated answer is VSME — the Voluntary Sustainability Reporting Standard for SMEs, developed by EFRAG and annexed to Commission Recommendation (EU) 2025/1710 of 30 July 2025. VSME doubles as the value-chain cap: large companies and banks are asked to limit what they demand from SME suppliers to what the standard covers. Our VSME hub walks through the standard, the CSRD comparison and a filled example report.
One number you will not find on this page is how many companies remain in scope across the EU. The estimates in circulation contradict each other, so we publish none. The only count that matters is the one you just ran against your own headcount and turnover — and if the result sits close to a threshold, group structure and averaging rules can tip it either way. That borderline case is exactly what we confirm on a short call.
The post-Omnibus question is not when you report — it is whether you are in scope at all.
Frequently asked.
Does CSRD still apply after the Omnibus?
Does CSRD apply to my company?
Is CSRD delayed or cancelled?
Who has to report CSRD in 2028?
What are the CSRD thresholds for 2027?
How does the CSRD 1,000 employees threshold work?
Settle your CSRD status in writing.
Send us your headcount, turnover and group structure. Habitat confirms whether CSRD, VSME or neither applies, maps your first reporting year, and puts scope, timeline and price in writing.