CSRD
Assess whether it is material and, if so, report it under the ESRS.
The duty is disclosure.EU reporting · two directives compared
CSRD vs CSDDD: reporting against due diligence
The CSRD requires in-scope undertakings to report sustainability information under the ESRS; the CSDDD requires in-scope companies to act on adverse human rights and environmental impacts.
Omnibus I amended both in 2026, and their scopes now differ: 1,000 employees and €450 million for the CSRD, 5,000 employees and €1.5 billion for the CSDDD.
The two meet in the double materiality assessment, where engagement carried out within due diligence is a key input, as at 11 October 2026.
At a glance
The CSRD and the CSDDD, side by side
Read the table by row: each line is a question a company asks, answered once for each directive, as amended by Omnibus I.
| Question | CSRD | CSDDD |
|---|---|---|
| What does it require? | Sustainability reporting in the management report, under the ESRS | Due diligence on adverse human rights and environmental impacts |
| Where is it? | Articles 19a, 29a and 40a of the Accounting Directive | Directive (EU) 2024/1760 |
| EU scope | Exceeds both 1,000 employees and €450m net turnover, from FY2027 | More than 5,000 employees and more than €1.5bn net worldwide turnover |
| Non-EU scope | Article 40a: EU turnover above €450m in two years plus an EU subsidiary or branch above €200m, from FY2028 | More than €1.5bn net turnover in the Union, no employee test |
| Applies from | FY2027 for the single test; wave one reported FY2024–26 | Transposition by 26 July 2028; application from 26 July 2029 |
| Climate transition plan | Reporting on a plan survives, under the ESRS | The Article 22 duty to adopt a plan was deleted |
| Enforcement | Limited assurance of the sustainability statement | Pecuniary penalties capped at 3% of net worldwide turnover |
| Civil liability | Not a CSRD feature | EU-wide regime removed; a matter of national law |
What each asks
One directive asks you to report; the other asks you to act
The CSRD is a reporting directive: it rewrote Articles 19a and 29a of the Accounting Directive to require sustainability information in the management report.
The CSDDD is a conduct directive: it requires due diligence on actual and potential adverse impacts.
Read what each duty means in practice
Under the CSRD, the topical ESRS apply only to the matters a double materiality assessment finds material, and the statement carries a limited assurance opinion.
Under the CSDDD, identification is risk-based and runs in two stages under Article 8(2), as amended by Omnibus I.
Termination of a business relationship was replaced by suspension as a last resort.
The due-diligence duty itself is set out on the CSDDD guide, and the reporting duty on the CSRD guide.
An adverse impact in the value chain
CSDDD
Identify it through the risk-based exercise, then act on it.
The duty is conduct.Who is in scope
Two thresholds, split apart by Omnibus I
The CSRD reaches undertakings that exceed both 1,000 employees and €450 million of net turnover from financial years beginning on or after 1 January 2027.
The CSDDD reaches EU companies with more than 5,000 employees and more than €1.5 billion of net worldwide turnover.
Read the scope detail
Recital 37 of Omnibus I records the CSDDD increase from €450 million to €1.5 billion and from 1,000 to 5,000 employees, so the old CSDDD figures are now the CSRD test.
A non-EU company is in CSDDD scope if its net turnover in the Union exceeded €1.5 billion in the financial year preceding the last, with no employee test.
A franchise or licensing limb also exists, for royalties above €75 million and net turnover above €275 million.
The CSDDD conditions must be met in two consecutive financial years (Article 2(5)).
The CSRD thresholds page reads an entity’s figures against the CSRD test with a scope checker.
ScopeExplore
Module 02 / 04
CSRD, non-EU
EU turnover above €450m in two years and an EU entity above €200m, from FY2028.
Dates
How the two directives arrive
The CSRD is already reporting; the CSDDD applies from 2029, and this chronology is as at 11 October 2026.
- 16 December 202201
- 202402
CSDDD adopted
Directive (EU) 2024/1760 on corporate sustainability due diligence, as its number records. - FY202403
- 18 March 202604
Omnibus I in force
Both directives amended: new thresholds, CSDDD Article 22 deleted. - 1 January 202705
- 19 March 202706
Omnibus CSRD transposition
Member States transpose Articles 1 to 3 of Directive (EU) 2026/470. - 26 July 202707
- 26 July 202808
- 26 July 202909
- 1 January 203010
The full CSRD sequence is on the CSRD timeline, and the 2026 amendments on the Omnibus I guide.
Climate transition plans
The CSDDD duty was deleted; the CSRD reporting survives
Omnibus I deleted Article 22 of the CSDDD, which had required companies to adopt a climate transition plan.
Reporting on a transition plan survives under the CSRD and the ESRS, for undertakings above the 1,000-employee and €450 million test.
Read the transition-plan detail
The ESRS climate standard, ESRS E1, is where an in-scope undertaking reports its plan or that it has none.
For UK groups, the FCA records at ¶2.36 of PS26/19 that UK SRS S2 does not require entities to have a climate-related transition plan.
Neither directive, as amended, now requires a company to adopt a plan.
Transition plansExplore
Module 02 / 04
CSRD
Reporting on a transition plan survives, for undertakings in scope.
Enforcement and liability
Penalties and liability, after Omnibus I
Under the CSDDD, Article 27(4) now caps pecuniary penalties at 3% of net worldwide turnover.
Under the CSRD, the sustainability statement in the management report carries a limited assurance opinion.
Read the liability detail
Omnibus I removed the EU-wide civil liability regime from the CSDDD, leaving liability to national law.
Where national law imposes liability, Article 29(2) keeps the right to full compensation.
Article 29(3)(d) and Article 29(7) were deleted, while joint and several liability remains in Article 29(5).
The CSRD assurance opinion and its standards are set out on assurance under the CSRD.
EnforcementExplore
Module 04 / 04
CSRD assurance
Limited assurance of the sustainability statement.
The value chain
Two different limits on asking suppliers for information
Each directive now limits what a company may ask of smaller business partners, and the two limits are different.
| Point | CSRD value-chain cap | CSDDD Article 8(2a) |
|---|---|---|
| Who is protected? | Undertakings with no more than an average of 1,000 employees in the preceding financial year | Business partners with fewer than 5,000 employees |
| What is limited? | Requests beyond the voluntary standard made for a customer’s CSRD reporting | Information requests, made only when it cannot reasonably be obtained by other means |
| Effect on the other directive | Does not affect due diligence obligations or information gathered for other purposes (recital 12) | A CSDDD rule; it does not change CSRD reporting |
The voluntary standard named in the CSRD cap is set out on the VSME guide.
A supplier protected by the CSRD cap can still receive a CSDDD request, because recital 12 keeps due diligence outside the cap.
Where they meet
Due diligence feeds the double materiality assessment
Revised ESRS 1 ¶42 says the results of engagement with affected stakeholders, “carried out in the context of ongoing sustainability due diligence activities”, are “a key input to the impact materiality assessment”.
That is the practical link between the two directives: one identification of adverse impacts can inform both.
Read how the two connect
The CSDDD asks the company to act on what it finds; the CSRD asks it to report what is material.
An impact can be material for CSRD reporting without the CSDDD applying, because the CSRD reaches far more companies.
How engagement feeds the impact assessment is on double materiality stakeholder engagement, and the workforce standard on ESRS S1.
All twelve standards are on the ESRS page.
Shared groundExplore
Module 01 / 04
ESRS 1 ¶42
Engagement within due diligence is a key input to impact materiality.
Module 04 / 04
Value-chain cap
The CSRD cap does not affect due diligence obligations.
One company, both directives
How one company runs both
A company in scope of both runs one due-diligence process and one double materiality assessment, and links them.
The sequence below is an illustration, not a timetable either directive prescribes.
Read the joint-programme detail
The CSDDD duty applies from 26 July 2029, so the CSRD assessment will often come first.
Where it does, the impacts already identified for the ESRS give the due-diligence process a starting point.
A group with ISSB-based reporting outside the EU has a third set of requirements, compared on the CSRD against the ISSB standards.
- 1
Confirm scope
Test the CSRD and CSDDD thresholds separately.
- 2
Identify impacts
One risk-based identification of adverse impacts.
- 3
Act
Act on the adverse impacts found, under the CSDDD.
- 4
Report
Assess materiality and report under the ESRS.
An illustrative sequence
One company, both directives
This sequence illustrates an EU company above both thresholds; it is not a statutory timetable.
- 01 / Scope01
Test both thresholds
CSRD: 1,000 employees and €450m; CSDDD: 5,000 employees and €1.5bn. - 02 / Identify02
Map adverse impacts
Risk-based, in two stages, across operations and the chain of activities. - 03 / Assess03
Double materiality
Engagement results from due diligence as a key input to the impact lens. - 04 / Report04
- 05 / Act05
- 06 / Report again06
UK groups
How a UK group meets either directive
Neither directive is UK law, so a UK group meets them only through its EU activity.
The CSRD reaches its EU subsidiaries on their own figures and, from FY2028, the group under Article 40a.
Read the UK detail
The CSDDD reaches a non-EU company with more than €1.5 billion of net turnover in the Union, without an employee test.
At home, a listed UK group reports against UK SRS on a comply-or-explain basis under PS26/19, which carries no due-diligence duty.
UK group routesExplore
Counting the years
Which year’s figures each test reads
The two directives do not read the same year’s figures, which matters for a company near a threshold.
The CSDDD applies only once its conditions are met in two consecutive financial years (Article 2(5)).
Read the year-counting detail
A non-EU company’s CSDDD test reads Union turnover in the financial year preceding the last.
The CSRD value-chain cap reads employee numbers in the preceding financial year, not the year being reported.
Reference yearsExplore
What goes wrong
Six mistakes in comparing the two
“The CSDDD threshold is 1,000 employees and €450m”
That is now the CSRD test; the CSDDD is 5,000 employees and €1.5bn.
“The CSDDD requires a transition plan”
Article 22 was deleted by Omnibus I; plan reporting survives under the CSRD.
“There is EU-wide civil liability”
The EU-wide regime was removed; liability is a matter of national law.
“Suppliers under 1,000 employees are off-limits”
The CSRD cap does not affect due diligence; the CSDDD has its own Article 8(2a) limit.
“Termination is the remedy”
Suspension replaced termination as the last resort.
“The CSDDD applies from 2027”
Transposition is due by 26 July 2028 and application from 26 July 2029.
A reading of the directives, not legal advice
National transposition can change the outcome for a particular company; this page reads the consolidated texts as at 11 October 2026.
What Omnibus I changed
One amending directive, two directives changed
Directive (EU) 2026/470 amended the CSRD and the CSDDD together, and it entered into force on 18 March 2026.
Member States transpose its CSRD articles by 19 March 2027 and its CSDDD article by 26 July 2028.
Read the amendment detail
For the CSRD, it set the single 1,000-employee and €450 million test and kept assurance at limited.
For the CSDDD, it raised the thresholds, deleted Article 22, removed the EU-wide civil liability regime and capped penalties at 3%.
The CSRD side is set out on the Omnibus I guide, and EFRAG’s part in the revised standards on the EFRAG guide.
Omnibus IExplore
Module 02 / 04
Article 4
Amends the CSDDD: thresholds, transition plans, liability, penalties.
Module 03 / 04
Stop-the-clock
Directive (EU) 2025/794 first postponed the later CSRD waves.
Frequently asked
Questions people ask
What is the difference between the CSRD and the CSDDD?
The CSRD requires in-scope undertakings to report sustainability information in the management report under the ESRS.
The CSDDD sets obligations for in-scope companies regarding actual and potential adverse human rights impacts and adverse environmental impacts (Article 1), found through a risk-based, two-stage identification under Article 8(2).
Who is in scope of the CSRD?
From financial years beginning on or after 1 January 2027, undertakings and groups that exceed both an average of 1,000 employees and a net turnover of €450 million.
Non-EU groups are reached separately under Article 40a from financial year 2028.
Who is in scope of the CSDDD?
As amended by Omnibus I, EU companies with more than 5,000 employees on average and a net worldwide turnover of more than €1.5 billion in the last financial year.
A non-EU company is in scope if it generated a net turnover of more than €1.5 billion in the Union in the financial year preceding the last, with no employee test.
Are the CSRD and CSDDD thresholds the same?
No, not any more.
Omnibus I raised the CSDDD thresholds to 5,000 employees and €1.5 billion, and set the CSRD test at 1,000 employees and €450 million.
The €450 million and 1,000-employee figures are now the CSRD test, not the CSDDD one.
When does the CSDDD apply?
Member States must transpose it by 26 July 2028 and apply it from 26 July 2029.
The reporting duty in Article 16 applies for financial years starting on or after 1 January 2030.
When does the CSRD apply?
Wave-one undertakings reported for financial years 2024 to 2026.
From financial years beginning on or after 1 January 2027 every undertaking follows the single test of 1,000 employees and €450 million, and Article 40a third-country reporting starts from financial year 2028.
Does the CSDDD still require a climate transition plan?
No. Omnibus I deleted Article 22 of the CSDDD entirely.
Transition-plan reporting survives under the CSRD and the ESRS for undertakings in its scope.
Is there civil liability under the CSDDD?
Omnibus I removed the EU-wide civil liability regime, so liability is a matter of national law.
Where national law imposes liability, Article 29(2) keeps the right to full compensation, and joint and several liability remains in Article 29(5).
What penalties does the CSDDD set?
Article 27(4), as amended, sets a maximum pecuniary penalty of 3% of the company’s net worldwide turnover.
The CSRD works differently: the sustainability statement sits in the management report and carries a limited assurance opinion.
Do CSDDD due diligence and CSRD materiality overlap?
Yes.
Revised ESRS 1 ¶42 says the results of engagement with affected stakeholders, carried out in the context of ongoing sustainability due diligence, are a key input to the impact materiality assessment.
One identification of adverse impacts can therefore inform both, though the CSDDD duty is to act and the CSRD duty is to report.
Does the CSRD value-chain cap limit CSDDD information requests?
No. Recital 12 of Omnibus I says the CSRD cap does not affect due diligence obligations or information gathered for other purposes.
The CSDDD has its own limit: Article 8(2a) restricts requests to business partners with fewer than 5,000 employees to information that cannot reasonably be obtained by other means.
Does a company have to end a business relationship under the CSDDD?
Not as a first step.
Omnibus I replaced mandatory termination with suspension of the relationship “as a last resort”, with enhanced action plans.
Does either directive apply to UK companies?
Only through EU activity.
A UK group is reached by the CSRD through EU subsidiaries above the threshold or under Article 40a, and by the CSDDD if it has more than €1.5 billion of net turnover in the Union.
Neither is UK law.
Is a company in scope of the CSDDD always in scope of the CSRD?
For EU companies, the CSDDD thresholds are higher on both limbs than the CSRD test, so an EU company over the CSDDD thresholds will also exceed the CSRD test.
This page reads the thresholds only; group structures, exemptions and national transposition can change the answer for a particular company.
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 11 sources fromEUR-LexFinancial Conduct AuthorityDepartment for Business and Trade
- EUR-LexDirective (EU) 2024/1760 (the CSDDD), consolidated 18 March 2026
Article 2 scope, Article 29 civil liability and Article 37 dates, as amended by Omnibus I.
- EUR-LexDirective (EU) 2024/1760, as adopted
The original text, before Omnibus I.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Articles 19a, 29a and 40a
Where the CSRD duty sits: the 1,000-employee and €450m test from FY2027.
- EUR-LexDirective (EU) 2022/2464 (the CSRD), OJ L 322, 16.12.2022
The amending directive that put sustainability reporting into the Accounting Directive.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
Amends both directives; in force 18 March 2026.
- EUR-LexDirective (EU) 2026/470, Official Journal text
Article 4 amends the CSDDD: Article 22 deleted, Article 8(2a) inserted, Article 27(4) and Article 29 amended; recital 37 on the new thresholds.
- EUR-LexDirective (EU) 2025/794 (stop-the-clock)
Postponed the later CSRD reporting waves before Omnibus I replaced them.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS
In force 10 November 2026; applies to financial years beginning on or after 1 January 2027.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the first ESRS
The set wave-one undertakings applied from FY2024.
- Financial Conduct AuthorityPS26/19 (PDF) — ¶2.36 on transition plans
UK SRS S2 does not require entities to have a climate-related transition plan.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures
The UK climate standard, for UK groups reporting beside the EU regimes.
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