CSRD reporting requirements for UK companies: who is caught after Omnibus I

Not to a UK company as such, because the CSRD is EU law.

It reaches a UK group in three ways: through an EU subsidiary (or EU sub-group parent) that exceeds 1,000 employees and €450m net turnover, through securities admitted to an EU regulated market where the issuer passes the same test, and, from financial year 2028, through Article 40a if the group has over €450m of EU turnover in each of the last two years and an EU subsidiary or branch over €200m.

From financial years beginning on or after 1 January 2027, an undertaking is in scope where it exceeds a net turnover of €450m and an average of 1,000 employees during the financial year.

Both limbs must be exceeded; it is “and”, not “or”.

Groups apply the same test on a consolidated basis under Article 29a.

No. A 1,750 figure circulated between the political agreement in December 2025 and the adopted text, and it does not appear in Directive (EU) 2026/470.

The adopted threshold is 1,000 employees and €450m net turnover.

The UK parent, at group level, must have generated net turnover in the EU exceeding €450m in each of the last two consecutive financial years, and it must have an EU subsidiary with net turnover over €200m in the preceding year or, if it has no such subsidiary, an EU branch over €200m.

The EU subsidiary or branch then publishes a report at the level of the UK group.

For financial years beginning on or after 1 January 2028, with the first reports published in 2029.

Because the turnover test looks back two years, a UK group’s 2026 and 2027 EU turnover decides whether it is caught for 2028.

The Commission has not yet adopted one.

EFRAG published the draft ESRS-40a on 23 July 2026, covering impacts only, with consultation to 31 October 2026 and technical advice due in January 2027; the Commission then consults before adopting a delegated act.

A group may instead report under the full ESRS or under standards the Commission declares equivalent.

Not on its own.

UK SRS uses single (financial) materiality, while the CSRD requires double materiality.

The routes that accept other standards — the Article 19a(9) and 29a(8) subsidiary exemption and the Article 40a alternative — require reporting under the ESRS or standards declared equivalent by a Commission implementing act, and no such act covering UK SRS appeared on EUR-Lex when checked on 11 October 2026.

For financial years beginning on or after 1 January 2027, the revised ESRS in Delegated Regulation (EU) 2026/1563, published on 21 September 2026.

For financial years starting in 2026 an undertaking already reporting may use the 2023 ESRS as amended by Delegated Regulation (EU) 2025/1416, the revised ESRS in full, or the 2023 ESRS with eight named reliefs, and must state which.

The Accounting Directive requires information needed to understand the undertaking’s impacts on sustainability matters and information needed to understand how sustainability matters affect the undertaking’s development, performance and position.

ESRS 1 turns this into impact materiality and financial materiality; a matter is material if it meets either.

Yes, limited assurance, under Article 34 of the Accounting Directive.

Omnibus I deleted the power to adopt reasonable assurance standards, so there is no legislated move to reasonable assurance.

The Commission must adopt limited assurance standards by 1 July 2027.

Article 40a reports must be published with an assurance opinion from a person authorised under the law of the third country or of a Member State.

Article 40a(3) accepts an assurance opinion from a person or firm authorised to give an opinion on the assurance of sustainability reporting under the national law of the third-country undertaking or of a Member State.

Whether a particular UK firm qualifies depends on that authorisation.

The CSRD imposes no obligation on suppliers.

A supplier with 1,000 employees or fewer is protected by the value-chain cap from financial years beginning on or after 1 January 2027: a reporter may ask for more than the voluntary standard covers, but must say which items exceed it and that the supplier may decline.

Any obligation to answer comes from the contract.

Yes.

Omnibus I amended the CSRD and the Accounting Directive; it did not repeal them.

Wave-one companies report for financial years 2024 to 2026, and from 2027 only undertakings over 1,000 employees and €450m remain in scope.

Directive (EU) 2025/794 postponed wave two to FY2027 and wave three to FY2028.

Omnibus I then limited wave one to financial years 2024 to 2026, so a wave-one company below the new thresholds drops out from 2027.

Member States may also exempt wave-one undertakings below €450m or 1,000 employees for FY2025 and FY2026.

In a clearly identifiable section of the management report, or the consolidated management report for groups, published under national law.

An Article 40a report is published by the EU subsidiary or branch within 12 months of the balance sheet date, through the business register or on its website.

Penalties are set nationally.

Article 51 of the Accounting Directive requires Member States to provide penalties that are effective, proportionate and dissuasive, so the sanction for a UK group’s EU subsidiary depends on the Member State where it is established.

The Commission’s staff working document SWD(2026) 500 estimates about 6,753 companies remain in scope after Omnibus I, of which 1,535 already reported under the 2023 ESRS, and says the scope change removes about 85% of companies from the original scope. These are Commission estimates, not a register.