Exceeds both
More than 1,000 employees on average and more than €450 million net turnover: in scope.
Art 19a(1); Art 29a(1) for groups.EU reporting · CSRD scope after Omnibus I
CSRD thresholds: who the CSRD reaches after Omnibus I
From financial years beginning on or after 1 January 2027, the CSRD reaches an undertaking that exceeds both an average of 1,000 employees and a net turnover of €450 million.
A parent applies the same test to its group on a consolidated basis, and a non-EU group is reached from FY2028 through its EU turnover.
The rule sits in the Accounting Directive as rewritten by Directive (EU) 2026/470, and the checker below reads your figures against it.
The test from FY2027
Two limbs, both exceeded
Article 19a(1) of the Accounting Directive, as consolidated on 18 March 2026, applies to undertakings that “exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year”.
The word is “and”, so the test is cumulative, and the word is “exceed”, so a figure equal to the threshold does not meet it.
Read the limb-by-limb detail
Article 29a(1) applies the same figures to a parent of a group, measured on a consolidated basis, and the duty is then to report for the group.
Employees are an average over the financial year, and turnover is net turnover as the Accounting Directive defines it.
The test applies to financial years beginning on or after 1 January 2027, so a calendar-year company first reports for 2027 in 2028.
What an in-scope undertaking then reports is set by the revised ESRS in Delegated Regulation (EU) 2026/1563, filtered by its double materiality assessment.
| Limb | Figure | Wording | Provision |
|---|---|---|---|
| Net turnover | More than €450 million | “exceed a net turnover of EUR 450 000 000” | Art 19a(1); 29a(1) consolidated |
| Employees | More than 1,000 on average | “and an average number of 1 000 employees during the financial year” | Art 19a(1); 29a(1) consolidated |
| Combination | Both | “and” | Cumulative |
| Start | Financial years from 1 January 2027 | Directive (EU) 2026/470 | Recitals 31 and 33 |
An EU undertaking or parent, FY2027 onwards
Meets one or neither
Not in scope on its own figures; check group reporting and the value-chain cap.
Exactly 1,000 or exactly €450m is not “exceed”.Which figures count
The CSRD thresholds use three different measurements
The same two numbers are measured on different bases depending on who is asking the question.
An EU undertaking uses its own figures, an EU parent uses consolidated group figures, and a non-EU group uses its turnover in the Union.
Read why the reference period matters
The scope test counts the average number of employees “during the financial year”, while the value-chain cap counts employees in the preceding financial year.
Article 40a looks back further still, to EU turnover in each of the last two consecutive financial years and to the subsidiary’s or branch’s turnover in the preceding year.
Mixing these periods can give the wrong answer about one entity, so record which year each figure comes from.
Whose figures, which yearExplore
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Own figures
An EU undertaking measures its own net turnover and average employees for the financial year.
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EU turnover
A non-EU group measures turnover generated in the Union, for each of the last two consecutive years.
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Preceding year
The value-chain cap counts employees in the preceding financial year, not the current one.
The test it replaced
The two-of-three “large undertaking” test is no longer the CSRD test
Much of what is still published about CSRD scope describes the two-of-three test: a balance sheet over €25 million, net turnover over €50 million, more than 250 employees.
That test is still law in Article 3(4) of the Accounting Directive, but from FY2027 it no longer decides who reports under the CSRD.
Read why the old figures still circulate
Before Omnibus I, the CSRD’s wave two reached every large undertaking on the two-of-three test, which is why those figures fill older guidance.
A further figure, 1,750 employees, circulated between the political agreement of December 2025 and the adopted text; it appears nowhere in Directive (EU) 2026/470.
The adopted test is 1,000 employees and €450 million, both exceeded.
The change from wave-based phasing to a single test is set out on the CSRD after Omnibus I.
Three tests, three jobsExplore
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Large undertaking
Exceed two of €25m balance sheet, €50m net turnover and 250 employees: still the Accounting Directive’s size class.
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Old CSRD wave two
Used the large-undertaking test before Omnibus I; replaced from FY2027.
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Value-chain cap
Protects undertakings that do not exceed 1,000 employees in the preceding year.
Before and after Omnibus I
What happened to the waves, year by year
The CSRD as adopted in 2022 phased reporting in by waves, the stop-the-clock directive pushed the later waves back, and Omnibus I replaced them with one test.
The timeline shows each step and the instrument behind it.
- 202201
CSRD adopted
Directive (EU) 2022/2464 phases reporting in by waves, starting with FY2024. - 26 February 202502
Omnibus I proposed
The Commission proposes narrowing CSRD scope and changing the standards. - 14 April 202503
Stop-the-clock
Directive (EU) 2025/794 moves wave two to FY2027 and wave three to FY2028. - 26 February 202604
Omnibus I published
Directive (EU) 2026/470 appears in the Official Journal; it enters into force on 18 March 2026. - 19 March 202705
Transposition deadline
Member States must bring Articles 1 to 3 into force. - FY202706
One test for everyone
Exceed both 1,000 employees and €450m; wave one outside that test leaves the CSRD. - FY202807
Third-country reporting
Article 40a applies; first reports are published in 2029. - 30 April 203108
Scope review due
The Commission reports on whether scope should be extended, then every three years.
Read the wave table
| Group | Original CSRD | After stop-the-clock | After Omnibus I |
|---|---|---|---|
| Wave one | FY2024 | FY2024 | FY2024–FY2026 only; from FY2027 the new test applies |
| Wave two | FY2025 | FY2027 | Replaced by the 1,000 and €450m test from FY2027 |
| Wave three | FY2026 | FY2028 | Replaced; the listed-SME standard was deleted |
| Non-EU groups | FY2028 | FY2028 | Article 40a from FY2028, on the new EU turnover tests |
Recital 31 of Omnibus I says undertakings inside the old wave-one scope but outside the new test “will fall outside the scope of this Directive as of financial years starting on or after 1 January 2027”.
For financial years starting in 2025 and 2026, Member States may exempt wave-one undertakings that fall below the new test, so the national transposition matters for those years.
Non-EU groups
Article 40a: two EU turnover tests, from FY2028
A group with no EU parent can still be reached, under Article 40a, if its EU turnover is large and it has a large EU subsidiary or branch.
The group’s net turnover in the Union must exceed €450 million for each of the last two consecutive financial years.
Read the Article 40a conditions
The subsidiary limb applies only to an EU subsidiary that exceeded a net turnover of €200 million in the preceding financial year.
A branch is used only where there is no such subsidiary, and only if the branch itself generated more than €200 million of net turnover in the preceding financial year.
Where the third-country undertaking is a financial holding undertaking whose subsidiaries’ business models and operations are independent of one another, Member States must let the subsidiaries and branches decide not to publish the report.
The reporting standard is a separate draft, ESRS-40a, which covers impacts only; the ESRS-40a page tracks its consultation, open until 31 October 2026 as at 11 October 2026.
Article 40aExplore
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Group EU turnover
More than €450m in each of the last two consecutive financial years.
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Or a branch
Only where there is no such subsidiary, with net turnover above €200m.
Exemptions and derogations
When an in-scope undertaking does not report itself
Meeting the thresholds is the start, not the end, of the scope question.
A subsidiary included in its parent’s consolidated sustainability reporting is often exempt from reporting separately.
Read the exemption conditions
Under Articles 19a(9) and 29a(8), an EU undertaking whose parent reports for it on a consolidated basis, under the ESRS or in a manner equivalent to them, is exempt on conditions that include publication of the parent’s report and its assurance opinion.
Article 29a(7a) lets a parent that is a financial holding undertaking, whose subsidiaries’ business models and operations are independent of one another, choose not to include the sustainability information in its consolidated management report.
Directive (EU) 2026/470 deleted Article 29c, the listed-SME standard, and the empowerment to adopt sector-specific standards; what remains is a recital-level possibility of non-binding sector guidance.
Each exemption has conditions that this page summarises rather than reproduces, so check the consolidated text and the national law that transposes it.
Ways out of reportingExplore
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Parent report
Included in a parent’s consolidated sustainability reporting to the ESRS or an equivalent: Art 19a(9) / 29a(8), on conditions.
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Financial holding
A parent whose subsidiaries’ businesses are independent may leave the information out of its consolidated report (Art 29a(7a)).
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Wave one, 2025–2026
Member States may exempt undertakings that fall below the new test.
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Deleted routes
No listed-SME standard and no sector ESRS: Article 29c and the sector empowerment were deleted.
Below the threshold
The value-chain cap protects the undertakings the CSRD no longer reaches
Undertakings below the scope test are often asked for data by those above it.
The value-chain cap protects an undertaking that does not exceed an average of 1,000 employees in the preceding financial year.
Read the cap’s limits
A CSRD reporter may not require more sustainability information from a protected undertaking, for its CSRD reporting, than the voluntary standard in Delegated Regulation (EU) 2026/1560 specifies.
The Commission’s note of 6 May 2026 says the cap “does not impose or imply any obligation on any companies in the value chain to provide sustainability information”.
Notice the reference period: the scope test counts employees during the financial year, while the cap looks at the preceding financial year.
What the capped questions are, and what a supplier can decline, is set out under the voluntary standard for SMEs.
- 1
A CSRD reporter asks
It needs value-chain information for its own statement.
- 2
The supplier is protected
It does not exceed an average of 1,000 employees in the preceding financial year.
- 3
The cap applies
Information beyond the voluntary standard may be declined.
- 4
No obligation created
The cap does not impose or imply any duty on the supplier.
How many companies
About 6,750 companies, on the Commission’s own estimate
The Commission’s staff working document SWD(2026) 500 estimates a population of 6,753 companies: 1,535 in wave one and 5,218 in wave two.
It describes that population as companies that will remain subject to CSRD reporting following the Omnibus I scope changes.
Read the caveats on the figure
The 6,753 is an estimate built for the cost analysis of the revised standards, not an official register of reporting companies.
Wave one and wave two are a cost distinction in the document: wave one had already reported under the 2023 ESRS, and wave two will report for the first time under the revised standards.
The same document says Omnibus I narrows scope to companies above 1,000 employees and €450 million turnover, “reducing the number of companies in scope by about 85%”.
Older figures in circulation describe the pre-Omnibus scope and are not repeated here.
The population estimateExplore
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Wave 2
5,218 companies reporting for the first time under the revised ESRS.
Scope is not materiality
Passing the CSRD thresholds decides whether, not what
The thresholds answer only the first of four questions an in-scope undertaking faces.
Which standards apply, what is material and how the statement is assured are separate questions with separate rules.
Read how the questions connect
For financial years starting in 2026, an undertaking may use the 2023 ESRS, the 2023 ESRS with eight reliefs, or the revised ESRS, and must say which; from FY2027 the revised ESRS apply.
Revised ESRS 1 ¶22 says the information disclosed is determined by the double materiality assessment, and ¶24 says information that is not material “shall not” be disclosed, except supplementary information.
The assurance opinion is a limited assurance engagement, and the reasonable-assurance path was removed by Omnibus I.
The method is on double materiality, and the count of datapoints that materiality filters is on ESRS datapoints.
Four separate questionsExplore
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Version
For FY2026 there are three options; from FY2027 the revised ESRS apply.
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Materiality
The double materiality assessment decides which information is reported.
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Assurance
The statement, and the process behind it, is subject to limited assurance.
UK groups
How the CSRD thresholds reach a UK group
No UK law imposes the CSRD; a UK group meets it only through the EU.
The usual routes are an EU subsidiary above the thresholds, an EU listing, or, from FY2028, Article 40a on the group’s EU turnover.
Read the UK detail
A UK parent with a large EU subsidiary may find the subsidiary in scope on its own figures, or exempt if the UK parent reports for it in an equivalent way.
UK listed companies report separately against UK SRS on a comply-or-explain basis for periods from 1 January 2027, which is a different regime with a different materiality test.
The comparison is set out in how the CSRD and UK SRS compare, and what a UK group has to do is on CSRD reporting for UK groups.
Routes for a UK groupExplore
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EU subsidiary
In scope on its own figures, or as an EU parent of its own sub-group.
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Value chain
A UK supplier to an EU reporter, protected by the cap if small enough.
Check whether an entity is in scope
Read your figures against the CSRD thresholds
The checker reads one entity’s figures against the thresholds, for the financial year you choose.
Choose whether you are checking an EU undertaking on its own figures, an EU parent on consolidated figures, or a non-EU group under Article 40a.
For FY2027 onwards it applies the two limbs strictly, so a figure equal to a threshold does not count as exceeding it.
For FY2026 and earlier it explains why the answer depends on your wave and on national law, rather than giving a yes or no.
It is a reading of the Directive’s thresholds, not legal advice, and nothing you enter is stored or sent.
CSRD thresholds · in-scope check
Enter employees and net turnover
Use the undertaking’s own figures (Art 19a(1)).
Rules: Directive 2013/34/EU Arts 19a(1), 29a(1), 19a(3), 19a(9), 29a(8) and 40a(1), consolidated 18 March 2026, as amended by Directive (EU) 2026/470. “Exceed” is strict: exactly 1,000 employees or exactly €450m is not in scope.
A reading of the Directive’s thresholds, not legal advice: national transposition (due by 19 March 2027) and the conditions of each exemption can change the outcome. Nothing you enter is stored or sent.
Doing the check properly
Five steps to settle CSRD scope for an entity
The thresholds are simple; applying them to a real group takes a few more decisions.
This sequence is an illustration of one way to order them, not a procedure the Directive prescribes.
- 01 / Entity01
Name the reporting entity
An EU undertaking, an EU parent of a group, or a non-EU group with EU activity. - 02 / Year02
Fix the financial year
FY2027 onwards uses the new test; earlier years depend on wave and national law. - 03 / Figures03
Measure both limbs
Average employees during the year and net turnover, consolidated for a parent. - 04 / Exemptions04
Test the exemptions
A qualifying parent report, the financial-holding derogations, national options. - 05 / Record05
Write the conclusion down
Keep the figures, the year and the provisions relied on, and revisit them each year.
What goes wrong
Six CSRD threshold mistakes
Using two of three
The €25m, €50m and 250 test is the Accounting Directive’s size class, not the CSRD test from FY2027.
Meeting one limb
Both 1,000 employees and €450m must be exceeded.
Treating “equal” as “exceed”
Exactly 1,000 employees or exactly €450m does not meet the test.
Quoting 1,750 employees
The figure is not in the adopted Directive.
Assuming wave one stays in
Wave one is limited to FY2024–FY2026 unless the new test is met.
Reading the cap as a duty
The value-chain cap protects suppliers; it creates no obligation on them.
After the scope question
Once an entity is in scope, what it reports is decided by its materiality assessment and the revised standards on the ESRS page.
The dates that follow, from the first financial year to first assurance, are on the CSRD timeline, and what the assurer checks is set out under assurance of CSRD reports.
Frequently asked
Questions people ask
What are the CSRD thresholds?
From financial years beginning on or after 1 January 2027, the CSRD reaches an undertaking that exceeds both a net turnover of €450 million and an average of 1,000 employees during the financial year.
A parent of a group applies the same test on a consolidated basis.
Both limbs must be exceeded; one is not enough.
Who does the CSRD apply to from 2027?
EU undertakings and EU parents of groups exceeding both €450 million net turnover and an average of 1,000 employees, under Articles 19a(1) and 29a(1) of the Accounting Directive as amended by Directive (EU) 2026/470.
Non-EU groups are reached separately under Article 40a from FY2028.
Is a company with exactly 1,000 employees in scope?
No. The Directive says “exceed”, so an average of exactly 1,000 employees, or exactly €450 million of net turnover, does not meet the test.
Do I need to meet one threshold or both?
Both.
The test is cumulative: net turnover above €450 million and more than 1,000 employees on average. It is not the old two-of-three test.
Does the CSRD still use the €25m, €50m and 250 employee test?
No. Those figures define a “large undertaking” in Article 3(4) of the Accounting Directive, which is still law, and they set the CSRD’s wave two before Omnibus I. From FY2027 the CSRD test is 1,000 employees and €450 million instead.
What happens to wave-one companies that fall below the new test?
Wave one is limited to financial years 2024 to 2026.
Recital 31 of Directive (EU) 2026/470 says undertakings inside the old wave-one scope but outside the new test fall outside the CSRD for financial years starting on or after 1 January 2027, and Member States may exempt them for 2025 and 2026.
When does the CSRD apply to non-EU companies?
Under Article 40a from financial years starting on or after 1 January 2028, with first reports in 2029, where the group’s EU net turnover exceeds €450 million in each of the last two consecutive financial years and it has an EU subsidiary, or failing that a branch, with net turnover above €200 million in the preceding year.
Is the 1,750-employee threshold correct?
No. A 1,750-employee figure circulated between the political agreement of December 2025 and the adopted text, and it appears nowhere in Directive (EU) 2026/470.
The adopted figure is 1,000 employees, combined with €450 million of net turnover.
How many companies does the CSRD cover now?
The Commission’s staff working document SWD(2026) 500 estimates 6,753 companies remaining in scope after Omnibus I, of which 1,535 are wave one and 5,218 are wave two.
It is an estimate of the post-Omnibus population used for cost analysis, not an EU-wide register, and the Commission says scope fell by about 85%.
Can a subsidiary rely on its parent’s report?
Often.
Articles 19a(9) and 29a(8) exempt an undertaking included in a parent’s consolidated sustainability reporting prepared under the ESRS or an equivalent standard, on conditions including publication of the parent’s report and assurance opinion.
The conditions need checking case by case.
Does the CSRD apply to UK companies?
Not through UK law.
A UK group meets it through an EU subsidiary or EU parent above the thresholds, an EU listing, or, from FY2028, Article 40a on its EU turnover.
Separately, UK listed companies report against UK SRS on a comply-or-explain basis from 2027.
What does the value-chain cap mean for suppliers below the threshold?
An undertaking that does not exceed an average of 1,000 employees in the preceding financial year may decline information beyond the voluntary standard when asked for a customer’s CSRD reporting.
The Commission says the cap does not impose or imply any obligation on companies in the value chain.
Is there still a listed-SME standard or sector ESRS?
No. Directive (EU) 2026/470 deleted Article 29c and the empowerment to adopt sector-specific standards.
The Commission may still give non-binding sector guidance.
When must Member States apply the new thresholds?
Directive (EU) 2026/470 requires Member States to bring Articles 1 to 3 into force by 19 March 2027.
The new scope test applies to financial years beginning on or after 1 January 2027.
Is the checker on this page legal advice?
No. It reads figures against the Directive’s thresholds.
National transposition, the reference year used and the conditions of each exemption can change the outcome.
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 12 sources fromEUR-LexEuropean CommissionEFRAG
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Arts 19a(1), 29a(1), 19a(3), 19a(9), 29a(8) and 40a(1)
The scope test as amended: exceed €450 million net turnover and an average of 1,000 employees; the value-chain cap; the exemptions; the third-country tests.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
Published 26 February 2026, in force 18 March 2026; transposition of Articles 1 to 3 by 19 March 2027.
- EUR-LexDirective (EU) 2026/470 — PDF, recitals 26, 31 and 33; Arts 2(13), 3(2)
Wave one limited to FY2024–FY2026; Article 40a; the scope review due by 30 April 2031.
- EUR-LexDirective (EU) 2022/2464 (the CSRD as adopted)
The original phasing that Omnibus I replaced.
- EUR-LexDirective (EU) 2025/794 (stop-the-clock), Art 1 and recital 3
Moved wave two to FY2027 and wave three to FY2028.
- European CommissionSWD(2025) 80 final — accompanying the Omnibus proposals of 26 February 2025
The date the Omnibus I package was proposed.
- European CommissionSWD(2026) 500 final — the revised ESRS staff working document
Estimates 6,753 companies remaining in scope after Omnibus I, about 85% fewer than originally.
- EUR-LexDirective 2013/34/EU Art 3(4) — the “large undertaking” size class
Still live law, but no longer the CSRD test.
- EUR-LexDelegated Regulation (EU) 2026/1560 — the voluntary standard
What a protected value-chain undertaking can be asked for.
- European CommissionAdditional explanatory information on the value chain cap, 6 May 2026
The cap “does not impose or imply any obligation” on companies in the value chain.
- EUR-LexDelegated Regulation (EU) 2026/1563 — the revised ESRS
What an in-scope undertaking reports from FY2027.
- EFRAGESRS-40a Exposure Draft — Basis for Conclusions
The draft standard for third-country groups; reporting from FY2028, first reports in 2029.
Continue reading
Read next
The directive
The CSRD explained
What the directive requires once an undertaking is in scope.
What changed
The CSRD after Omnibus I
Old and new scope side by side, and what else changed.
Dates
CSRD timeline
Every date from adoption to first reports and assurance.
Standards
ESRS E1 climate
The climate standard most in-scope undertakings report against.