From FY2027
Exceed €450m net turnover and an average of 1,000 employees, both.
Directive 2013/34/EU Art 19a(1)CSRD consultants · after Omnibus I
CSRD consultancy does a UK group need it?
CSRD consultancy is worth buying only once you know which entity in your group reports, because Omnibus I took most companies out of scope.
Start with a scope memo, then brief the work the revised ESRS and limited assurance actually require.
UK SRS is an independent reference site. We have assessed no consultancy and publish no consultancy prices or rankings.
The first question
Do you need CSRD consultancy at all?
CSRD consultancy answers a narrower question for a UK group than it did before Omnibus I: which, if any, of our entities reports, from which year, and against which standards.
A UK group meets CSRD through an EU subsidiary, an EU parent, Article 40a for non-EU groups, or as a supplier, and only the first three create a reporting duty.
Read the detailed guidance and references
Choose the route that matches your group and the checker below says who files, using the thresholds in the consolidated Accounting Directive.
If no route applies, you do not need CSRD consultants; you may still need help answering customer questionnaires, which is a different purchase.
The UK picture is set out on CSRD reporting for UK companies, and the regime itself on the CSRD guide.
CSRD · which route are you in?
Pick the position that fits.
A UK group can stand in more than one: test each EU subsidiary on its own figures and the whole group under Article 40a.
Rules: Directive 2013/34/EU Arts 19a, 29a and 40a and Directive (EU) 2022/2464 Art 5, as amended by Directive (EU) 2026/470.
“Exceed” is strict and both limbs are needed.
Nothing you enter leaves your browser.
A provisional reading, not advice on your group perimeter.
Four routes into CSRDExplore
Module 01 / 04
EU subsidiary
An EU entity over both thresholds.
Module 02 / 04
EU parent
Your UK company feeds its report.
Module 03 / 04
Article 40a
Large EU turnover, from FY2028.
Module 04 / 04
Supplier
A customer’s request, not a duty.
Scope after Omnibus I
1,000 employees and €450 million
Directive (EU) 2026/470, in force since 18 March 2026, limits CSRD from financial year 2027 to undertakings that exceed a net turnover of €450 million and an average of 1,000 employees.
The test is cumulative, so an undertaking over one limb and under the other is out of scope.
Read the detailed guidance and references
Wave one is limited to financial years 2024 to 2026, so a company that reported early stays in only if it meets the new test, according to recital (31) of the Official Journal text.
For financial years 2025 and 2026, Member States may exempt undertakings that do not exceed €450 million or 1,000 employees, which is wider than the scope test and differs country by country.
A “1,750 employees” threshold circulated between the political agreement and the adopted text, and it does not appear in the act.
The Commission’s staff working document SWD(2026) 500 estimates that 6,753 companies remain in scope and that the change removes about 85% of the original scope.
That population counts only companies that remain subject to CSRD after Omnibus I, not every company a UK group might meet in its value chain.
Before the Omnibus the stop-the-clock Directive (EU) 2025/794 had moved wave two to FY2027 and wave three to FY2028; the history is on the CSRD Omnibus page.
Which test is in the proposal?
Superseded for CSRD
Two of €25m balance sheet, €50m turnover and 250 employees.
Art 3(4): still the “large” size classNon-EU parents
Article 40a: the third-country test
A UK-parented group with large EU sales can be caught by Article 40a, which applies where the group generated net turnover in the Union of more than €450 million in each of the last two consecutive financial years.
The report is then published through an EU subsidiary with more than €200 million of net turnover, or a branch over €200 million where there is no such subsidiary.
Read the detailed guidance and references
There is no employee test at either limb of Article 40a(1).
Reporting under Article 40a begins with the 2028 financial year, with first reports in 2029, according to EFRAG.
The standards for it are an EFRAG exposure draft covering impacts only, with consultation open until 31 October 2026 and technical advice expected in January 2027, as set out in its Basis for Conclusions.
Where the third-country undertaking is a financial holding undertaking whose subsidiaries are independent of one another, Member States must let the subsidiaries and branches decide not to publish.
An EU subsidiary can be exempt from its own report where it is included in a consolidated report of its third-country parent prepared under the ESRS or an equivalent, under Article 19a(9).
The draft standard is on ESRS-40a.
Article 40a · scope check · € millions
No answer without the EU-generated turnover figures
Limb 1 is the whole of the first question: net turnover generated in the Union, at group level, for each of the last two financial years.
Most consolidated accounts do not present that number, because "EMEA" or "Europe" is not the Union.
Producing it is the first piece of work.
Rule: Directive 2013/34/EU Art 40a(1), as amended by Directive (EU) 2026/470 Art 2(13).
“Exceeding” is strict: €450.0m is not over the line.
A provisional reading of published thresholds, not a determination for your group.
Two limbs, no employee testExplore
Module 01 / 04
Group
Over €450m EU turnover in each of two years.
Module 02 / 04
Subsidiary
An EU subsidiary over €200m.
Module 03 / 04
Branch
Over €200m, only if no such subsidiary.
Module 04 / 04
Standards
ESRS-40a, still a draft.
The standards
The simplified ESRS, and the FY2026 choice
The revised ESRS are Delegated Regulation (EU) 2026/1563, published on 21 September 2026, in force on 10 November 2026 and applying to financial years beginning on or after 1 January 2027, under its Article 3.
For FY2026 an undertaking may use the 2023 ESRS, the 2023 ESRS with eight listed reliefs, or the revised ESRS, and must state which (Article 2).
Read the detailed guidance and references
The Commission said on 3 July 2026 that the revision cuts mandatory datapoints by over 60%.
Under the revised ESRS 1, an undertaking shall not disclose information required by a disclosure requirement or datapoint if it is not material (¶24), and may reach top-down conclusions on materiality (¶27).
The voluntary standard for undertakings protected by the value-chain cap is Delegated Regulation (EU) 2026/1560, in force since 24 September 2026.
Paragraph numbers changed between versions, so a gap analysis or template built on the 2023 ESRS needs re-mapping before it is used for FY2027.
The standards are set out on ESRS, and the voluntary standard on VSME.
Revised ESRSExplore
Module 01 / 04
Published
Official Journal, 21 September 2026.
Module 02 / 04
In force
10 November 2026.
Module 03 / 04
Applies
Financial years from 1 January 2027.
Module 04 / 04
FY2026
Three versions to choose from.
Double materiality
Double materiality decides the rest
ESRS reporting rests on double materiality, so the assessment is the first substantive package a CSRD consultancy delivers and it decides every disclosure that follows.
The revised ESRS 1 says that in general the starting point is the assessment of impacts (¶36), with engagement with affected stakeholders in ongoing due diligence a key input (¶42).
Read the detailed guidance and references
Severity is assessed on scale, scope and irremediable character (¶40), and the materiality of risks and opportunities on likelihood and the potential magnitude of financial effects (¶50).
UK SRS uses single (financial) materiality, asking what could reasonably be expected to affect cash flows, access to finance or cost of capital, at UK SRS S1 ¶3.
The concept is explained on double materiality, and running one on the double materiality assessment guide.
- 1
Impacts first
“In general, the starting point is the assessment of impacts” (ESRS 1 ¶36).
- 2
Severity
Scale, scope and irremediable character (¶40).
- 3
Financial
Likelihood and potential magnitude of financial effects (¶50).
Assurance and independence
Limited assurance, and who may not prepare the report
CSRD assurance is limited assurance: Omnibus I removed the empowerment to adopt reasonable assurance standards (recital 5), and the Commission must adopt limited assurance standards by 1 July 2027.
The statutory auditor gives the opinion by default, and each Member State may allow a different auditor or an independent assurance services provider, under Article 34 of the consolidated Accounting Directive.
Read the detailed guidance and references
The opinion covers compliance with the ESRS, the process used to identify the information reported and the Taxonomy Article 8 disclosures, so those are inside the assurance perimeter.
For a public-interest entity, the audit rules list preparing sustainability reporting among the prohibited non-audit services, in Article 5(1)(c) of Regulation (EU) No 537/2014 as amended by the CSRD.
Directive 2006/43/EC Article 25c, inserted by the CSRD, applies that prohibition to the auditor carrying out the assurance of a public-interest entity’s sustainability reporting and to its network.
So if your auditor will assure the report, your CSRD adviser has to be someone else, and that choice should come first.
The UK side of assurance is on sustainability assurance.
Keep preparer and assurer apartExplore
Module 01 / 04
Level
Limited assurance only.
Module 02 / 04
Standards
Commission due by 1 July 2027.
Module 03 / 04
Provider
Statutory auditor, or a Member State option.
Module 04 / 04
Independence
The assurer may not prepare it.
National law
Transposition: 27 answers by 19 March 2027
Member States must bring Articles 1 to 3 of Omnibus I into national law by 19 March 2027, under its Article 5(1).
On 11 October 2026 the EUR-Lex transposition listing showed notified measures from four Member States: Belgium, Croatia, Poland and Finland.
Read the detailed guidance and references
The deadline has not passed, so a Member State with nothing notified is not late.
A notified measure is not necessarily a complete transposition, and the listing states that Member States bear sole responsibility for the information.
The delegated regulations that set the ESRS need no transposition, because a regulation applies directly.
A CSRD consultant should name the Member State whose law applies to each reporting entity, and say where that law is not yet final.
Directive, then national lawExplore
Module 01 / 04
Directive
In force 18 March 2026.
Module 02 / 04
Deadline
19 March 2027 for Articles 1 to 3.
Module 03 / 04
Options
Assurance provider and FY2025–26 relief.
Module 04 / 04
Regulations
The ESRS apply directly.
Interoperability
CSRD and UK SRS: one dataset, two regimes
The ESRS–ISSB interoperability guidance says the definition of financial materiality in ESRS is aligned with IFRS S1, on which UK SRS S1 is built, while ESRS also covers the impact materiality lens.
The same guidance says almost all the climate disclosures in ISSB Standards are included in ESRS, which is not the same as saying the reverse.
Read the detailed guidance and references
The guidance dates from 2 May 2024 and maps the 2023 ESRS, so its paragraph tables need re-reading against the revised ESRS.
A UK-listed group in UKLR 6, 14, 15, 16 or 22 reports against UK SRS on a comply-or-explain basis from periods beginning on or after 1 January 2027, under the FCA’s PS26/19.
A group in both regimes is best served by one data model mapped to each, rather than two parallel programmes and two assurance files.
The comparison is on CSRD and UK SRS compared, and UK-side help on UK SRS consultancy.
Aligned definition, different regimeExplore
Module 01 / 04
Definition
Financial materiality aligned with IFRS S1.
Module 02 / 04
Impact lens
ESRS adds it; UK SRS does not.
Module 03 / 04
Climate
Almost all ISSB climate disclosures are in ESRS.
Module 04 / 04
Basis
UK SRS is comply or explain for listed companies.
The engagement
What CSRD consultants actually deliver
A CSRD engagement for an in-scope entity runs in six packages, from perimeter mapping to an evidence file for limited assurance.
Each one rests on a named provision, which is the test of whether a proposal is scoped to the law as it now stands.
Read the detailed guidance and references
Stage 1 of 6
Perimeter
Subsidiary, sub-group, parent or Article 40a, entity by entity.
Requests to suppliers sit inside the value-chain cap, which lets undertakings of up to 1,000 employees decline requests beyond the voluntary standard.
The Commission said on 6 May 2026 that the cap does not impose or imply any obligation on companies in the value chain to provide sustainability information.
Until rules on marking up sustainability reporting are adopted, undertakings should not be required to mark it up, according to recital (24) of Omnibus I.
Searches for an ESRS consultant, CSRD reporting consultant or CSRD advisory firms describe the same engagement.
Six work packagesExplore
Module 01 / 04
Perimeter
Which entity reports.
Module 02 / 04
Materiality
Impacts, risks and opportunities.
Module 03 / 04
Data
Mapped once, within the cap.
Module 04 / 04
Assurance
Evidence for a limited opinion.
Before you call anyone
How to brief and judge a CSRD consultancy
Brief a CSRD consultancy with the entities, their turnover and headcount, the first reporting year, the Member State and who will assure the report, because those facts decide the work.
Answer the questions and the panel says whether you need a CSRD adviser at all, lists the work packages, and flags the claims that describe superseded law.
Read the detailed guidance and references
Ask each firm to state the scope test it applied, entity by entity, with the figures.
Ask which ESRS version the work is built on, and whether templates from the 2023 ESRS have been re-mapped.
Ask whether the firm, or anyone in its network, is or would be your statutory auditor or assurance provider.
Ask for days by grade, perimeter mapping priced separately from drafting, and who owns the workings at the end.
Proposals that use the 250-employee test, a 1,750-employee threshold or reasonable assurance from 2028 are working from law that has changed.
The wider process is in how to choose a sustainability consultant, and an unranked directory is on sustainability consulting firms.
What this page does not do
It names no firm, quotes no price and decides no entity’s scope.
Do you need a CSRD adviser, and for what?
The panel below starts from a UK group with an EU subsidiary; change any answer and it updates.
Scope memo first
Test each EU subsidiary, or the EU sub-group, against both limbs: more than €450 million net turnover and an average of more than 1,000 employees, from financial year 2027.
Directive 2013/34/EU Arts 19a(1), 29a(1)
First reporting year
An in-scope undertaking reports for financial years beginning on or after 1 January 2027 under the revised ESRS, with the first reports in 2028.
DR (EU) 2026/1563 Art 3; Directive 2022/2464 Art 5(2), as amended
Double materiality
A double materiality assessment under the revised ESRS 1 is the first substantive package, and it decides every disclosure that follows.
DR (EU) 2026/1563 Annex I, ESRS 1 Chapter 3
Gap analysis and data
Map the existing SECR and climate data to the revised ESRS, and plan value-chain requests within the cap.
Directive 2013/34/EU Art 19a(3), as amended; Directive (EU) 2026/470 recital (12)
Assurance and independence
Assurance is limited assurance.
If your statutory auditor will assure a public-interest entity’s sustainability reporting, it and its network may not also prepare that reporting, so the CSRD adviser must be someone else.
Directive 2013/34/EU Art 34(1); Regulation (EU) No 537/2014 Art 5(1)(c); Directive 2006/43/EC Art 25c
Red flags in a proposal
Scope written as two of €25 million, €50 million and 250 employees; a “1,750 employees” threshold; reasonable assurance phasing in; or a national deadline stated as final before your Member State has transposed. Each describes law that has changed.
Directive 2013/34/EU Art 3(4); Directive (EU) 2026/470 Art 2(4)(a), recital (5), Art 5(1)
A briefing aid that decides no scope and gives no legal advice; national law may add to it.
Nothing you choose is stored or sent.
A brief worth pricingExplore
Module 01 / 04
Entities
Name each EU entity and its figures.
Module 02 / 04
Year
FY2026 choice or FY2027 start.
Module 03 / 04
Assurer
Who assures, chosen first.
Module 04 / 04
UK SRS
Whether the group also reports in the UK.
Illustrative brief · no consultancy assessed
A worked brief: a UK group with one large EU subsidiary
This illustrative group owns a German subsidiary that exceeds both thresholds and is not a wave-one reporter.
Its CSRD consultancy brief names the scope memo, a double materiality assessment under the revised ESRS for FY2027, a data gap analysis, the sustainability statement and assurance readiness, with the auditor excluded from preparation.
For the detailed requirements, see CSRD reporting for UK companies.
View the workflow diagram
- 1
Scope
The EU subsidiary is tested against both limbs on its own figures.
- 2
Materiality
A double materiality assessment under the revised ESRS.
- 3
Assurance
Limited assurance from a provider that did not prepare it.
Each date has a different meaning
The CSRD dates in order
Check whether each date is a publication, an entry into force, an application date or a deadline for Member States.
- 18 March 202601
- 21 September 202602
Revised ESRS published
DR (EU) 2026/1563 and the voluntary standard in the Official Journal. - 31 October 202603
- 10 November 202604
Revised ESRS in force
Applies from financial years beginning on or after 1 January 2027. - 1 January 202705
- 19 March 202706
- 1 July 202707
- 1 January 202808
A suggested delivery sequence
From the scope memo to the handover
This is an editorial buying and preparation sequence, not a statutory timetable or a promise about how long the engagement takes.
- 01 / Scope01
Scope memo
Test each entity and name the Member State law that applies. - 02 / Assurer02
Choose the assurer
Decide who assures before anyone prepares. - 03 / Materiality03
Double materiality
Assess impacts, risks and opportunities under the revised ESRS. - 04 / Data04
Gap analysis and data
Map existing data once; request value-chain data within the cap. - 05 / Statement05
Sustainability statement
Draft the material disclosures in the management report. - 06 / Handover06
Handover
Keep the workings, the materiality record and the evidence file.
Frequently asked
CSRD consultants, answered
Does CSRD apply to UK companies?
Not directly to a UK company as such.
CSRD reaches a UK group through an EU subsidiary or EU sub-group that exceeds both €450 million net turnover and an average of 1,000 employees, through an EU parent that does, or, from financial year 2028, through Article 40a where the group has more than €450 million of EU turnover in each of the last two years and an EU subsidiary or branch over €200 million.
What does a CSRD consultant do?
A CSRD consultant maps which entities in the group report, runs or supports the double materiality assessment under the revised ESRS, analyses gaps in data and controls, helps draft the sustainability statement and prepares the evidence for limited assurance.
The undertaking remains responsible for its report.
Do we still need CSRD help after the Omnibus?
Only if an entity in your group is still in scope or you supply data to one that is.
Omnibus I narrowed scope from financial year 2027 to undertakings exceeding both 1,000 employees and €450 million net turnover, and the Commission estimates the change removes about 85% of companies from the original scope.
What are the CSRD thresholds after the Omnibus?
An undertaking reports if it exceeds a net turnover of €450 million and an average of 1,000 employees during the financial year, both together.
The 250-employee, €50 million and €25 million test is the Accounting Directive’s definition of a large undertaking and no longer defines CSRD scope; a “1,750 employees” figure that circulated is not in the adopted text.
Which ESRS version applies?
The revised ESRS in Delegated Regulation (EU) 2026/1563 apply to financial years beginning on or after 1 January 2027.
For FY2026 an undertaking may use the 2023 ESRS, the 2023 ESRS with eight listed reliefs, or the revised ESRS, and must state which.
Is CSRD assurance limited or reasonable?
Limited.
Omnibus I removed the empowerment to adopt reasonable assurance standards, and the Commission must adopt limited assurance standards by 1 July 2027.
Member States decide whether a different auditor or an independent assurance services provider may give the opinion.
Can our auditor also be our CSRD consultant?
Not for a public-interest entity whose sustainability reporting it assures.
The audit rules list preparing sustainability reporting among the prohibited non-audit services, and Directive 2006/43/EC Article 25c applies the prohibition to the auditor carrying out the assurance and its network.
Other entities are subject to the general independence rules.
Do suppliers to CSRD companies need a CSRD consultant?
Usually not.
The value-chain cap lets undertakings of up to 1,000 employees decline requests beyond the voluntary standard, and the Commission has said the cap does not impose or imply any obligation on companies in the value chain to provide information.
Can one adviser cover CSRD and UK SRS?
Yes, if it can show both.
The financial-materiality definition in ESRS is aligned with IFRS S1, on which UK SRS is built, but ESRS adds impact materiality and more climate datapoints, while UK SRS is comply or explain for listed companies from 2027.
How much does CSRD consultancy cost?
This site publishes no prices and has assessed no firm.
Ask for a sterling day rate by grade, a scope by work package, perimeter mapping priced separately from ESRS drafting, and the second year priced in the same proposal.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 18 sources fromEUR-LexEuropean CommissionEFRAGEFRAG and IFRS FoundationFinancial Conduct AuthorityDepartment for Business and Trade
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
In force 18 March 2026; transposition by 19 March 2027 (Art 5(1)); reasonable-assurance empowerment removed (recital 5).
- EUR-LexDirective (EU) 2026/470, Official Journal PDF
Recitals (12), (24), (31); Arts 2(13), 3(2), 6.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026, Arts 3(4), 19a, 29a, 34, 40a
The 1,000-employee and €450m test, Article 40a and the assurance provider options.
- EUR-LexDirective (EU) 2022/2464 (CSRD)
The original directive and its amendments to the audit legislation.
- EUR-LexDirective (EU) 2025/794 (stop the clock)
Moved wave two to FY2027 and wave three to FY2028.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 (revised ESRS)
In force 10 November 2026; applies to financial years beginning on or after 1 January 2027.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 (voluntary standard)
In force 24 September 2026; the value-chain cap datapoints.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 (ESRS, 2023)
The first set, still available for FY2026.
- European CommissionCommission adopts revised sustainability reporting standards (3 July 2026)
Over 60% fewer mandatory datapoints.
- European CommissionAdditional explanatory information regarding the value chain (6 May 2026)
The cap does not impose or imply any obligation on companies in the value chain.
- European CommissionSWD(2026) 500 final
6,753 companies remain in scope; about 85% fewer than the original scope.
- EUR-LexNational transposition measures for Directive (EU) 2026/470
Re-read 11 October 2026.
- EUR-LexRegulation (EU) No 537/2014, consolidated, Art 5(1)(c)
Preparing sustainability reporting is a prohibited non-audit service.
- EFRAGESRS for certain non-EU undertakings (Article 40a): project page
Exposure draft; consultation closes 31 October 2026.
- EFRAGESRS-40a Exposure Draft, Basis for Conclusions (July 2026)
Impacts only; first reports for FY2028.
- EFRAG and IFRS FoundationESRS–ISSB Standards Interoperability Guidance (2 May 2024)
Financial-materiality definition aligned; ESRS adds the impact lens.
- Financial Conduct AuthorityPS26/19
UK SRS on a comply-or-explain basis for listed companies from 2027.
- Department for Business and TradeUK SRS S1 (PDF), ¶¶3, 18
Single (financial) materiality.
Continue reading
Read next
EU
CSRD
The directive after Omnibus I.
EU
CSRD Omnibus
What changed, and when.
UK groups
CSRD reporting for UK companies
Which UK groups report, and what.
Comparison
CSRD and UK SRS compared
For groups that may meet both regimes.
Materiality
Double materiality
Impact and financial materiality, explained.
Standards
ESRS
The standards, revised for FY2027.