EU CSRD · UK companies · after Omnibus I
CSRD in the UK: four routes in, and who files
CSRD reporting in the UK is never a UK obligation: the Corporate Sustainability Reporting Directive is EU law, and it reaches a UK company only through something the company has in the EU.
Since Directive (EU) 2026/470 came into force on 18 March 2026, those routes are narrower, and three of the four are decided at group level, not by looking at the UK company in front of you.
This page is the scoping step: which route you are on, who files, and on which financial year.
Where it reaches
Four routes into CSRD, and no others
A UK company with no EU subsidiary, no EU branch, no securities on an EU regulated market and no EU customer asking for data is not in it.
| Route | The test | Who files | What the UK entity does |
|---|---|---|---|
| 1 · Consolidated into an EU parent | The EU parent group exceeds €450m and 1,000 employees, consolidated (Art 29a) | The EU parent, at group level | Supplies data into the group statement |
| 2 · A UK group with EU subsidiaries | Each EU subsidiary tested on its own figures (Art 19a), or an EU sub-group consolidated (Art 29a) | The EU subsidiary | Provides group data and controls |
| 3 · Securities on an EU regulated market | The issuer exceeds €450m and 1,000 employees | The issuer itself | Reports on its own behalf under the ESRS |
| 4 · Article 40a | EU turnover above €450m in each of two years, plus a €200m EU subsidiary or branch; no employee test | The EU subsidiary or branch publishes | Prepares the group report the EU entity publishes, from FY2028 |
| Value chain | An in-scope EU customer asks for data | Nobody — no filing | Answers a request, up to a statutory ceiling |
The single most common reason a UK finance team reaches the wrong answer is testing the company in front of it when the rule is testing the group above it.
Across all routes the filing entity is rarely the UK entity, and getting that wrong is expensive in the other direction: a reporting capability built that was never going to be used.
Route 4 surprises people most, because the obligation sits on the non-EU group but is discharged by an EU subsidiary or branch publishing the report — a UK head office writes it and a Dublin or Amsterdam entity puts its name to it.
Route finder
Which route are you standing in?
Pick the position that fits and enter the figures for the entity the rule actually tests.
“None of them” is a real answer: most UK companies meet the CSRD only as suppliers.
The logic follows Articles 19a, 29a and 40a of the Accounting Directive as amended by Omnibus I.
A group perimeter is a question for your own advisers, and the answer here is provisional, not a determination.
For Article 40a in depth, including the branch fallback and three worked examples, go to the Article 40a test for non-EU groups.
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.
What changed on 18 March 2026
Omnibus I cut the population by about 85%
Directive (EU) 2026/470 was dated 24 February 2026, published on 26 February and in force on 18 March 2026.
The turnover and headcount thresholds rose, the listed-SME wave was deleted outright, and the Article 40a group threshold went from €150 million to €450 million.
The Commission’s staff working document of July 2026 puts the effect at removing about 85% of companies from the original scope, and counts 6,753 that remain.
Its February 2025 working document modelled the proposal rather than the adopted text, which is why older figures differ.
The timing moved twice: Directive (EU) 2025/794 postponed the second and third waves, and Omnibus I then applied the second-wave rule to every in-scope undertaking for financial years starting on or after 1 January 2027.
The CSRD after Omnibus I page sets the old and new provisions side by side, and the CSRD explainer covers the Directive itself.
- 26 Feb 2025Omnibus I proposed
With staff working document SWD(2025) 80.
- 14 Apr 2025“Stop the clock”
Directive (EU) 2025/794 postpones waves two and three.
- 18 Mar 2026Omnibus I in force
Scope narrowed; law, not a proposal.
- 21 Sep 2026Revised ESRS published
DR (EU) 2026/1563, applying from FY2027.
- 19 Mar 2027Transposition deadline
Articles 1–3.
Article 4 runs to 26 July 2028.
- FY2027Every remaining undertaking reports
First reports 2028.
- FY2028First Article 40a year
Reports published 2029.
The size test
€450m and 1,000 employees — not two out of three
The old test was two of three: 250 employees, €50 million net turnover and €25 million balance sheet. It is gone.
What replaced it is conjunctive, and the word in the Directive is “and”.
Both limbs must be exceeded: a group at exactly 1,000 employees does not exceed 1,000.
There is no asset test left in Article 19a or 29a, so a page still giving you one predates 18 March 2026.
Article 29a applies the same pair on a consolidated basis, so a holding company with nine staff can carry a 4,000-employee group across the line.
A Member State may exempt undertakings that do not exceed €450 million or 1,000 employees for financial years starting in 2025 and 2026 — note the “or” — so for those years the answer depends on the country.
“Undertakings which, on their balance sheet dates, exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year shall include in their management report information necessary to understand the undertaking’s impacts on sustainability matters…”
Transposition
Two transposition deadlines, and everyone quotes one
A directive binds Member States, which then write it into national law; until they do, the national rule is the old one.
Omnibus I, Article 5(1), sets 19 March 2027 for Articles 1, 2 and 3 — the audit directive, the Accounting Directive and the CSRD — and 26 July 2028 for Article 4, the due diligence amendments.
The Commission repeats the 19 March 2027 date in the explanatory memorandum to C(2026) 5010.
For a UK group the practical consequence is that a Dutch subsidiary and an Irish one can be on different footings during 2026 and 2027.
The standards themselves need no transposition: the revised ESRS are a regulation, directly applicable once they apply.
Routes 1 to 3
Consolidation, your own EU subsidiaries, an EU listing
Route 1 is the commonest and the least dramatic: a UK company inside an EU parent group acquires a data obligation to somebody else’s filing.
There is no UK filing, no UK ESRS statement and no UK assurance engagement; what you owe is emissions, workforce figures, policies and the evidence trail an assurance provider will ask for.
The group’s materiality assessment covers you, and you are a data source in it, not a separate assessment.
Route 2 runs the other way: an EU subsidiary of a UK group that exceeds the pair on its own figures reports in its own right, on its Member State’s timetable.
Such a subsidiary can be exempt where the UK parent reports on the whole group under the ESRS or an equivalent standard, subject to conditions in Articles 19a(9) and 29a(8).
Route 3 catches a UK issuer admitted to trading on an EU regulated market, which Omnibus I tests as an issuer on the same €450 million and 1,000-employee pair.
A multilateral trading facility or growth market is not a regulated market, and nothing turns on where the primary listing sits.
A UK issuer can therefore sit inside the FCA’s UK SRS population and inside the CSRD at once, on two different clocks.
Route 4
Article 40a: the route with no employee test
A UK-headquartered group can be caught without a single EU-incorporated parent, purely on what it sells into the EU.
It needs EU net turnover above €450 million in each of the last two consecutive financial years, and an EU subsidiary — or, failing one, an EU branch — above €200 million in the preceding year.
Because the test looks back two years, the years that decide a first report for financial year 2028 are 2026 and 2027, and you are inside the first of them now.
The report will be written to a separate draft standard, ESRS-40a, which EFRAG is consulting on until 31 October 2026.
Omnibus I added a final subparagraph to Article 40a(1): where the non-EU undertaking is a financial holding undertaking whose subsidiaries’ “business models and operations are independent of one another”, Member States “shall ensure that the subsidiaries and the branches may decide not to publish” the report.
It lands through national law and the phrase is not defined, so put it in front of counsel in the relevant Member State rather than assuming it.
| Financial year | Role in the test |
|---|---|
| FY2026 | Measured — in progress |
| FY2027 | Measured |
| FY2028 | First reporting year |
| 2029 | First report published |
Roles
Who files, who assures, and who just sends spreadsheets
Across the four routes the UK entity is rarely the one that files.
These are the roles the Directive creates, and who holds each on each route.
| Role | Routes 1 and 2 · EU parent or EU subsidiary | Route 3 · EU-listed issuer | Route 4 · Article 40a |
|---|---|---|---|
| Files the statement | The EU undertaking, in its management report | The issuer | The EU subsidiary or branch, publishing a report on the non-EU group |
| Writes the content | The EU undertaking, with data from the rest of the group | The issuer | In practice the group head office; the EU entity publishes |
| Assures it | By default its statutory auditor; other providers only where its Member State allows | As for routes 1 and 2 | An assurance opinion is required under Article 40a(3) |
| Standard | The revised ESRS | The revised ESRS | ESRS-40a, still a draft |
| The UK entity’s job | Supply data, controls and evidence on the EU timetable | Report on its own behalf | Produce the group report and the EU-turnover figure |
The assurance row is where Member States differ most: the Directive makes the statutory auditor the default and lets each Member State decide whether another auditor or an independent assurance services provider may sign.
A group with subsidiaries in three Member States can therefore face three answers to “who may assure us”, and should ask before it tenders.
The spreadsheet row is the one most UK finance teams actually live in: a data calendar set by somebody else’s filing deadline, with an assurance provider testing the evidence behind each number.
The best preparation for that role is unglamorous — a controlled emissions inventory, a workforce data set with definitions written down, and an audit trail.
The value chain
What an EU customer can actually require of you
Since 18 March 2026 there is a statutory ceiling on CSRD questionnaires, and a statutory right to decline what sits above it.
The mechanism, in the Directive’s own words.
| The rule | Where | |
|---|---|---|
| Who is protected | An undertaking that “does not exceed, on its balance sheet date, an average number of 1 000 employees during the preceding financial year” and is in a reporter’s value chain. No turnover limb. | Art 19a(3) |
| Self-declaration | The reporter “may rely on a self-declaration” and “shall not be required to take steps to verify” it, unless it is manifestly incorrect. | Art 19a(3) |
| Right to decline | A protected undertaking may decline information exceeding the voluntary standard, when asked for CSRD reporting. | Art 19a(3)(a) |
| Contract clauses | “Any contractual provision contrary to point (a) shall not be binding”; the rest of the contract stands. | Art 19a(3)(b) |
| Asking for more | The reporter must say “which information exceeds” the cap and tell you of your “statutory right to decline”. | Art 19a(3)(c) |
| The reporter is covered | A reporter that takes no over-cap information from protected undertakings is “deemed to have complied”. | Art 19a(3)(d) |
The cap bites only on requests made for CSRD reporting; it expressly does not affect requests “for the purpose of complying with Union requirements on undertakings to conduct a due diligence process”.
It imposes no obligation on any value-chain undertaking to report at all, and it does not touch financing conditions or an unrelated contract term.
On timing, the right to decline is in the Directive and binds once the customer’s Member State transposes it; what counts as “too much” is the Annex II list in Delegated Regulation (EU) 2026/1560, in force since 24 September 2026 and applying from financial years beginning on or after 1 January 2027.
The Commission’s explanatory note of 6 May 2026 covers the same ground; the “deemed to have complied” wording is the Directive’s, not the note’s.
If you fell out of scope
A half-built CSRD programme is not wasted
Many groups hired, bought software and ran a first double materiality assessment before Omnibus I took them out of mandatory scope.
Falling out of scope is not a reason to stop measuring, because in-scope EU customers still need value-chain data.
The voluntary standard adopted with the revised ESRS is now the reference framework for companies outside scope.
The emissions inventory, the governance record and the controls carry across to UK reporting; what does not carry across is the impact half of the assessment.
The UK SRS readiness assessment shows where that work lands on the UK side, and ESG reporting covers the voluntary frameworks around it.
A collision of names
“CSRD S1” is not IFRS S1, and the difference is total
Two standard-setters numbered standards S1 and S2 about the same subject, for different purposes.
A board paper that says “we are doing S1 and S2” is ambiguous until somebody names the regime.
Under the CSRD it means workforce and value-chain workers; under UK SRS S1 and S2 it means general requirements and climate, and the two do not overlap at all.
The ISSB issued IFRS S1 and IFRS S2 in June 2023, and the IFRS Sustainability Standards Navigator holds the texts; the ESRS page sets out the EU numbering.
| Under CSRD (ESRS) | Under UK SRS / IFRS | |
|---|---|---|
| S1 is… | Own Workforce | General requirements |
| S2 is… | Workers in the Value Chain | Climate |
| Climate sits in | ESRS E1 | S2, the whole standard |
| Numbering | ESRS 1, ESRS 2, E1–E5, S1–S4, G1 | IFRS S1 and S2, endorsed as UK SRS S1 and S2 |
Beside UK SRS
CSRD and UK SRS: neither discharges the other
Same IFRS ancestry, different scope, materiality and legal footing.
The UK column reflects the FCA’s final rules of 30 September 2026.
| EU CSRD / ESRS | UK SRS S1 and S2 | |
|---|---|---|
| Legal status | EU law; Omnibus I in force since 18 March 2026 | Voluntary standards since 25 February 2026; FCA listing rules require comply-or-explain reporting |
| From | FY2027 for Arts 19a/29a (Wave 2); FY2028 for Art 40a | Accounting periods beginning on or after 1 January 2027; first reports 2028 |
| Who | Above €450m net turnover and 1,000 employees; Art 40a on EU turnover | Listed companies in UKLR 6, 14, 15, 16 and 22; nobody else is required |
| Basis | Mandatory disclosure where material | Comply or explain across all disclosures; one-year Scope 3 and two-year S1 reliefs |
| Materiality | Double — impact and financial | Financial only |
| Standards | Revised ESRS, DR (EU) 2026/1563 | IFRS S1 and S2 with UK amendments |
| Assurance | Limited assurance; the path to reasonable assurance was deleted | Not required; state whether obtained and, if so, by whom and to which standard |
| For whom | Investors and other stakeholders, including civil society | Primary users of general purpose financial reports |
UK SRS asks what could affect the entity’s cash flows, access to finance or cost of capital; the CSRD asks that, and also what the entity does to people and the environment.
The second question is not a harder version of the first but a different one, with different evidence; double materiality explains the two lenses and the double materiality assessment how to run one.
The joint ESRS–ISSB interoperability guidance says the financial-materiality definitions are aligned while the regimes are not, because the ESRS add the impact lens.
The practical rule is one sentence: share the data, separate the assessments.
The UK side is set out in the government’s UK SRS guidance, on what comply or explain requires, in the size tests people confuse with UK SRS scope and in the dated UK SRS register.
Your own dates
Which reporting year bites first for your year-end
Both regimes attach to financial years that begin on or after a date, not to calendar years, so a March or September year-end moves everything.
The rows below are our arithmetic from the stated rules.
| Year-end | CSRD, Arts 19a and 29a | CSRD, Art 40a | FCA UK SRS rules (listed) |
|---|---|---|---|
| 31 December | Year from 1 January 2027; report in 2028 | Year from 1 January 2028; report in 2029 | Period from 1 January 2027; annual financial report by 30 April 2028 |
| 31 March | Year from 1 April 2027; report in 2028 | Year from 1 April 2028; report in 2029 | Period from 1 April 2027; annual financial report by 31 July 2028 |
| 30 June | Year from 1 July 2027; report in 2028 | Year from 1 July 2028; report in 2029 | Period from 1 July 2027; annual financial report by 31 October 2028 |
| 30 September | Year from 1 October 2027; report in 2028–29 | Year from 1 October 2028; report in 2029–30 | Period from 1 October 2027; annual financial report by 31 January 2029 |
For a 31 December company the two regimes line up: the first UK SRS period and the first CSRD year for a remaining undertaking both begin on 1 January 2027.
For every other year-end, the first year in scope is the first one that begins after that date, so a 31 March group’s first year starts on 1 April 2027 and ends on 31 March 2028.
The UK column applies only to companies listed in UKLR 6, 14, 15, 16 or 22, and its first year may use the FCA’s one-year Scope 3 relief and two-year climate-first relief, stated rather than explained.
The Article 40a column follows a draft standard; the thresholds that decide it are law, and the first reporting year is EFRAG’s timetable.
A group whose EU subsidiary uses a different year-end from the parent needs this table twice, once for each entity.
Work out your own years
Your first year under each regime, from your year-end
The table above covers four common year-ends; the planner beside this text covers all twelve.
Pick the month your financial year ends and it prints the first year the revised ESRS apply, the two years Article 40a measures and the year it reports, and the first period under the FCA’s UK SRS rules with its annual financial report deadline.
It assumes twelve-month years ending on the last day of a month, and it is arithmetic from the rules, not a ruling on your group.
Two cautions travel with it.
The EU publication date for a CSRD statement is set by each Member State’s transposing law, so the planner gives the year that is reported, not the day the report is due.
The Article 40a rows rest on EFRAG’s draft timetable for a standard the Commission has not adopted; the thresholds that decide them are law already.
Your first year under each regime
CSRD · Articles 19a and 29a
1 January 2027 to 31 December 2027
The first year the revised ESRS apply, and the first CSRD year for an in-scope undertaking that did not report in the first wave.
Publication follows your Member State’s transposing law.
CSRD · Article 40a, measured
1 January 2026 to 31 December 2026, then 1 January 2027 to 31 December 2027
EU net turnover must exceed €450m in each of these two years; the EU subsidiary or branch is measured on the second.
CSRD · Article 40a, reported
1 January 2028 to 31 December 2028
The first reporting year on EFRAG’s draft timetable, published the following year by the EU subsidiary or branch.
UK SRS · FCA rules (listed only)
1 January 2027 to 31 December 2027
Comply or explain against UK SRS; the annual financial report is due by 30 April 2028.
Rules: Directive (EU) 2026/470 recital 31 and Delegated Regulation (EU) 2026/1563 Art 3 (financial years beginning on or after 1 January 2027); Directive 2013/34/EU Art 40a(1) and the ESRS-40a Basis for Conclusions BC11 (financial years from 1 January 2028); FCA PS26/19 ¶3.12 and DTR 4.1.3R.
Dates for year-ends other than 31 December are our arithmetic from those rules, for twelve-month years.
A provisional reading, not advice.
Nothing is stored or sent.
Once you are in
What an in-scope entity actually produces
Scope is only the first question; the second is what the entity in scope must write, and it is easy to overestimate.
It produces a sustainability statement in a dedicated section of its management report, prepared to the ESRS and covered by a limited assurance opinion.
ESRS 1 and ESRS 2 apply to every reporter, and each of the ten topical standards applies only where the double materiality assessment finds the topic material.
The revised ESRS, which apply from financial years beginning on or after 1 January 2027, say information that is not material shall not be disclosed, so the statement is shorter than a 2023-era gap analysis suggests.
For a financial year starting in 2026 there are three versions to choose from, and the statement must say which was used.
The Taxonomy disclosures in Article 8 of Regulation (EU) 2020/852 come with it: they bind undertakings subject to Articles 19a and 29a, and they sit inside the same assurance opinion.
The full list of requirements, with the FY2026 choice and the assurance rules, is on CSRD reporting requirements for UK companies.
UK companies in non-EU groups
A UK subsidiary of a US or Swiss group is tested through its parent
Many UK companies sit inside groups headquartered outside both the UK and the EU, and the routes apply to them through the group, not through themselves.
The group’s EU subsidiaries are tested on their own figures under Articles 19a and 29a, exactly as a UK group’s would be.
Article 40a looks at the ultimate non-EU parent: its group’s EU turnover and its EU subsidiaries or branches decide the test, and the report is prepared at the level of that ultimate parent or its group.
A UK subsidiary in such a group is not the parent and does not run the Article 40a test itself; it supplies data into a report an EU entity of the group would publish.
The one case where a UK company’s own figures decide matters is the value chain: whether it is a protected undertaking turns on its own average headcount in the preceding financial year.
A UK intermediate holding company with EU subsidiaries beneath it should still map them, because their own CSRD obligations do not depend on where the ultimate parent sits.
The UK equivalent
Is there a UK CSRD? Not as such
There is no single UK law that does what the CSRD does, and asking for “the UK equivalent” usually means one of three things.
If it means the standards, the UK counterpart of the ESRS is UK SRS S1 and S2, published by the Department for Business and Trade on 25 February 2026 for voluntary use.
If it means the obligation, the closest thing is the FCA’s listing rules, which since PS26/19 ask listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis.
If it means company-law reporting for large private companies, the UK has SECR and the climate-related financial disclosure duties in the Companies Act, which are older, narrower and not standards-based in the same way.
No private-company threshold for UK SRS is proposed anywhere, and the government’s consultation on modernising corporate reporting runs from 7 September to 30 November 2026.
So the honest answer is that the UK has standards like the ESRS’s, applied to a narrower population, on a different materiality basis, through a different instrument; modernising corporate reporting tracks what may change.
Emissions
One inventory, two questions asked of it
Scope 1, 2 and 3 are defined by the GHG Protocol, not by either regime, so the underlying numbers are the same numbers.
A group caught by both needs one inventory with enough granularity for the more demanding question, and a control environment that can evidence it to an assurance provider.
The trap is Scope 2: UK SRS S2 requires the location-based figure, while ESRS E1 wants both methods.
SECR still applies at home, and the SECR reporting guide shows how that inventory is already reported.
For transition plans under both regimes, see climate transition plans.
| ESRS E1 | UK SRS S2 | |
|---|---|---|
| Scope 1 | Gross, where climate is material | Required |
| Scope 2 | Location-based and market-based | Location-based required; market-based permitted |
| Scope 3 | Where material | Required; one-year FCA relief |
| Transition plan | The plan, or a statement that there is none | Information about any plan the entity has |
CSRD readiness for UK companies
Four positions a UK group can be in, and the first step in each
Readiness starts with the perimeter, not the standards.
The position decides which work is needed at all.
| Position | What applies | First step |
|---|---|---|
| UK operations only, UK-listed | The FCA’s UK SRS rules on a comply-or-explain basis from periods beginning on or after 1 January 2027; no CSRD filing | A gap analysis against UK SRS S2, and a decision on which disclosures you will explain rather than make |
| UK operations only, not listed | UK SRS is voluntary; SECR and ESOS still apply where their own tests are met; EU customers may still ask for data | Answer customer requests against the EU voluntary standard, and decline what exceeds it if you are protected |
| UK parent with EU subsidiaries | Each EU subsidiary tested on €450m and 1,000 employees; the group tested separately under Article 40a | Map the perimeter: every EU subsidiary and branch, with turnover and headcount, and the group’s EU-generated turnover |
| UK subsidiary of an EU parent | Consolidation into the parent’s CSRD statement | Agree the data calendar with the parent; your UK filings do not change |
Four practical steps follow, in this order.
First, map the group perimeter: EU subsidiaries, EU branches and any securities admitted to an EU regulated market, each tested on its own numbers.
Second, run the materiality work early, because the financial half serves UK SRS and the impact half is the part only the CSRD asks for.
Third, build the data once: Scope 1, 2 and material Scope 3, workforce data and value-chain data, with controls an assurance provider can test.
Fourth, run UK SRS in parallel if you are listed, since the first UK period and the first remaining-undertaking CSRD year both begin in 2027 for a calendar-year group.
A group planning EU expansion should run the Article 40a test before the expansion rather than after it, because the turnover test looks back two years.
A plan for a UK parent
The next twelve months, quarter by quarter
An order of work for a calendar-year UK group with EU subsidiaries and EU sales.
The sequence follows the rules on this page; the quarters are our indicative suggestion.
| Quarter | Work | Rule it serves |
|---|---|---|
| Q4 2026 | Map every EU subsidiary and branch with turnover and headcount; produce EU-generated net turnover for 2026; decide whether to respond to the ESRS-40a consultation by 31 October | Arts 19a, 29a and 40a |
| Q1 2027 | Confirm which entities file for FY2027 and under which Member State law; agree the UK SRS approach if listed, including which disclosures you will explain | Omnibus I recital 31; FCA PS26/19 |
| Q2 2027 | Run the double materiality assessment for in-scope EU entities; build one emissions inventory with both Scope 2 methods | Revised ESRS 1 and E1; UK SRS S2 |
| Q3 2027 | Agree assurance providers Member State by Member State; send protected-undertaking self-declarations from UK trading companies to EU customers | Art 34; Art 19a(3) |
| Q4 2027 | Close the year with controls operating; re-run the Article 40a test on 2026 and 2027 figures | GOV-4; Art 40a(1) |
The plan front-loads the cheap, decisive work: the perimeter and the EU-turnover figure decide whether everything after them is needed at all.
It keeps the assessment and the inventory early because both have to exist before a year’s data can be captured against them.
And it puts the Article 40a test at the end of 2027 because that is when the second of the two measured years closes for a calendar-year group.
A listed group can run the UK SRS work in the same rhythm, because its first UK SRS period also begins on 1 January 2027.
Doing the work
Advisers and software: what UK groups actually buy
UK-facing CSRD engagements usually open with a group-perimeter exercise: which UK entities consolidate into an EU parent, whether the group crosses Article 40a, and which EU entity would publish.
From there the work is a double materiality assessment, a gap analysis of existing UK SRS and SECR data against the revised ESRS, and the controls needed to sustain limited assurance; sustainability assurance covers the last.
No UK adviser publishes a CSRD rate card, so this page prints no prices: ask for a sterling day rate, a milestone-based scope, and perimeter mapping priced separately from ESRS drafting.
On software, the mandatory datapoint set fell by over 60% on the Commission’s own figure, so a platform marketed on the size of its 2023 datapoint library is selling the wrong thing.
A group caught by both regimes should buy once, because the inventory, governance record and transition plan serve UK SRS S2 and ESRS E1 alike; carbon reporting software compares platforms.
The standard-setters’ own pages are the EFRAG sustainability reporting hub and the Commission’s corporate sustainability reporting page; the global sustainability standards page and UK sustainability reporting place both regimes in context.
PwC UK on CSRD reporting requirements and Novata on the UK standards.
Neither is relied on for any fact on this page.
To talk your own perimeter through, book a free 15-minute call, or start from the UK SRS reference.
Test yourself
Six claims about CSRD in the UK, checked
Each of these statements appears in commentary aimed at UK companies, and each is settled by a provision named beside it.
The first is the most expensive to get wrong in either direction: some UK groups ignore CSRD entirely, and others build a filing capability they will never use.
The second and third changed on 18 March 2026, which is why pages written in 2024 and 2025 still print the old tests.
The fifth changed on 30 September 2026, when the FCA finalised rules that differ from its own consultation.
The sixth is a deletion from the law rather than a delay, and it matters to anyone budgeting for assurance.
CSRD and UK SRS: true or false?
After Brexit, CSRD cannot apply to any UK company.
The CSRD size test after Omnibus I is two out of three criteria.
A UK supplier with 800 employees can decline an EU customer’s request that goes beyond the voluntary standard.
Reporting under UK SRS satisfies a CSRD obligation.
UK SRS S2 is mandatory for UK-listed companies from 2027.
CSRD assurance will move to reasonable assurance in 2028.
0 of 6 answered.
Nothing you choose is stored or sent.
If none of the four routes applies
Why an out-of-scope UK group still meets the ESRS
Being outside all four routes removes the filing obligation, not the questions.
EU customers in scope need value-chain data for their own statements, and the cap limits what they can require, not what they can ask.
EU lenders and investors may ask for data for their own purposes, which the cap expressly does not reach.
A group growing its EU sales should watch Article 40a, because two strong years can bring it in without any decision being taken.
And Omnibus I asks the Commission to assess, by 30 April 2031, whether scope should extend to large undertakings below the line and to non-EU undertakings selling directly into the Union.
None of that is a reason to build an ESRS statement nobody has asked for; it is a reason to keep an emissions inventory and a short set of sustainability data that answers the common questions well.
In short
Six things worth remembering
One: the CSRD is EU law with no effect in the UK, and it reaches a UK company only through something the company has in the EU.
Two: the size test is €450 million of net turnover and an average of 1,000 employees, both exceeded; the old two-of-three test is gone.
Three: the filer is usually an EU entity, and the UK company’s job is data, controls and evidence on someone else’s timetable.
Four: Article 40a has no employee test, looks back two years, and starts with financial year 2028 on EFRAG’s draft timetable.
Five: a protected supplier can decline what exceeds the voluntary standard when asked for CSRD purposes.
Six: neither UK SRS nor the CSRD discharges the other, but one inventory and one control environment can serve both.
What is still moving
Four dated things, and one door not yet built
31 October 2026: the ESRS-40a consultation closes, and what Article 40a groups will report against is not fixed until the Commission adopts it.
10 November 2026: the revised ESRS enter into force, though nothing in them is mandatory before financial years beginning on or after 1 January 2027.
28 October 2026: comments close on the FCA’s draft guidance on how to explain, Technical Note 803.1, on the UK side.
19 March 2027: Member-State transposition, after which your EU subsidiary’s obligation is its national law.
And no date set: Omnibus I requires the Commission to assess extending scope to large undertakings below the €450 million and 1,000-employee line and to non-EU undertakings “operating directly on the Union internal market without a subsidiary or a branch”, reporting by 30 April 2031.
Frequently asked
Questions people ask
Does CSRD apply to UK companies?
Not as UK law.
The CSRD is an EU directive with no effect in the UK.
It reaches a UK company only through the EU: an EU parent group or EU subsidiary that is in scope, securities on an EU regulated market, Article 40a for a non-EU group with large EU turnover, or data requests from EU customers.
A UK company with none of those is outside it.
Is my UK subsidiary of an EU parent caught by CSRD?
Indirectly.
If the EU parent group exceeds €450 million of net turnover and an average of 1,000 employees on a consolidated basis, it reports at group level and your UK company is inside that consolidated statement.
The UK company does not file; it supplies data and evidence on the group’s timetable.
What are the CSRD thresholds after Omnibus I?
An undertaking, or a group on a consolidated basis, must exceed both a net turnover of €450 million and an average of 1,000 employees during the financial year.
There is no balance-sheet limb and no two-of-three test any more.
For a non-EU group, Article 40a asks for EU net turnover above €450 million in each of the last two consecutive financial years and an EU subsidiary or branch above €200 million, with no employee test.
From which financial year does CSRD reporting start for a UK group’s EU subsidiary?
For an undertaking that remains in scope after Omnibus I and did not report in the first wave, financial years starting on or after 1 January 2027, with the first report in 2028.
Omnibus I limits the first wave’s obligation to financial years 2024 to 2026 and applies the second-wave rule to everyone in scope from 2027.
The subsidiary’s actual obligation is its Member State’s transposing law, due by 19 March 2027.
Can UK SRS reporting satisfy CSRD, or the other way round?
No. CSRD requires a sustainability statement to the ESRS on a double materiality basis.
UK SRS, based on IFRS S1 and S2, applies financial materiality only, and the FCA’s rules ask listed companies to report against UK SRS.
One emissions inventory and one control environment can serve both; one assessment cannot.
Do UK suppliers to EU companies have to comply with CSRD?
No. A supplier has no CSRD filing obligation.
Since 18 March 2026 the Directive also limits what an in-scope customer can require: a supplier that does not exceed an average of 1,000 employees in the preceding financial year is a protected undertaking, may decline information beyond the voluntary standard, and must be told which requested information exceeds it.
Is the EU Omnibus actually law?
Yes.
Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026.
Member States must transpose Articles 1 to 3 by 19 March 2027 and Article 4, the due diligence limb, by 26 July 2028.
What is the difference between CSRD S1 and IFRS S1?
They are unrelated standards that share a number.
Under the CSRD, ESRS S1 is Own Workforce and ESRS S2 is Workers in the Value Chain, while climate is ESRS E1.
Under UK SRS and IFRS, S1 is general requirements and S2 is climate.
"S1 and S2" is ambiguous until the regime is named.
Can a UK financial holding group avoid Article 40a?
Possibly.
Omnibus I added a derogation: where the non-EU undertaking is a financial holding undertaking whose subsidiaries’ business models and operations are independent of one another, Member States must ensure its EU subsidiaries and branches may decide not to publish the report.
It is delivered through national law and the key phrase is undefined, so it is a question for counsel.
Which financial years decide Article 40a scope?
The two most recent consecutive financial years.
For a first reporting year of 2028, that means 2026 and 2027, so a group near the €450 million line is being measured now.
What does CSRD readiness mean for a UK company?
Mapping the group perimeter first: which EU subsidiaries and branches exist, their turnover and headcount, any securities on an EU regulated market, and the group’s EU-generated turnover for Article 40a.
Only then does it make sense to plan a double materiality assessment, data systems and assurance, because the position decides which work is needed at all.
Does CSRD apply to a UK company with an EU branch but no EU subsidiary?
Only through Article 40a, and only where the group generated more than €450 million of net turnover in the EU in each of the last two years and the branch itself exceeds €200 million.
A branch is reached only where there is no EU subsidiary above that figure.
A branch does not make the UK company an EU undertaking for Articles 19a and 29a.
Do UK companies need CSRD compliance software?
Only a group with an actual CSRD route needs software built for the ESRS.
Most UK companies meet the CSRD through customer questionnaires, which the voluntary standard caps.
A group caught by both CSRD and the FCA’s UK SRS rules should buy one inventory and governance record that serves UK SRS S2 and ESRS E1 alike, rather than two systems.
Is the CSRD value-chain cap in force?
The right to decline has been in the Directive since 18 March 2026.
The voluntary standard that defines the ceiling, Delegated Regulation (EU) 2026/1560, has been in force since 24 September 2026, and its datapoint limit applies from financial years beginning on or after 1 January 2027.
Could CSRD reach UK companies with no EU subsidiary or branch in future?
Omnibus I requires the Commission to assess extending scope to non-EU undertakings operating directly on the Union internal market without a subsidiary or a branch, and to large undertakings below the €450 million and 1,000-employee line, with a report due by 30 April 2031.
No such extension exists today.
Which companies does CSRD apply to?
From financial years beginning on or after 1 January 2027, EU undertakings and EU parent groups that exceed both €450 million of net turnover and an average of 1,000 employees, issuers on EU regulated markets on the same test, and — from financial year 2028 — non-EU groups caught by Article 40a.
The Commission counts 6,753 companies remaining in scope.
What is the UK equivalent of the CSRD?
There is no single equivalent.
The UK’s standards are UK SRS S1 and S2, published by the Department for Business and Trade for voluntary use; the obligation to use them is the FCA’s comply-or-explain rule for listed companies from 2027; and company-law duties such as SECR sit alongside.
UK SRS uses financial materiality, not double materiality.
Is CSRD still applicable after the Omnibus?
Yes, to a much smaller population.
Omnibus I narrowed scope rather than repealing the Directive: the Commission estimates it removed about 85% of companies from the original scope, and the revised ESRS apply to those that remain from financial years beginning on or after 1 January 2027.
What changed in CSRD in 2026?
Omnibus I entered into force on 18 March 2026, narrowing scope to €450 million and 1,000 employees and adding the value-chain cap; the revised ESRS were published on 21 September 2026 and enter into force on 10 November 2026; the voluntary standard entered into force on 24 September 2026; and EFRAG published the ESRS-40a exposure draft on 23 July 2026.
Does CSRD apply to a UK subsidiary of a US company?
Not to the UK subsidiary itself.
The US group’s EU subsidiaries are tested on their own figures, and Article 40a is tested at the level of the US ultimate parent’s group.
A UK subsidiary supplies data into whatever an EU entity of the group reports, and is tested only as a value-chain supplier for the cap.
Does CSRD require Scope 3 emissions?
Where climate is material, ESRS E1 asks for gross Scope 1, 2 and 3 emissions, with Scope 3 for each significant category and Scope 2 on both the location-based and market-based methods.
UK SRS S2 also covers Scope 3, and the FCA’s rules give a one-year relief from disclosing it.
Does UK SRS reporting need to be assured?
No. Under the FCA’s final rules a listed company reporting against UK SRS states whether it obtained assurance and, if so, names the provider, which disclosures were assured and which assurance standard was used.
CSRD reporting, by contrast, requires a limited assurance opinion.
Does an EU branch make a UK company a CSRD reporter?
Not under Articles 19a and 29a, which apply to EU undertakings.
A branch matters only under Article 40a, as the fallback EU foothold where the non-EU group has no EU subsidiary above €200 million, and the branch then publishes the group report.
When should a UK group start preparing for CSRD?
Now, if it has any route in.
The perimeter and the EU-turnover figure are cheap and decisive; the first CSRD year for remaining undertakings begins on or after 1 January 2027, and the two years that decide a first Article 40a report are 2026 and 2027.
Does the CSDDD apply to UK companies?
Only to a UK company that meets its third-country test: more than €1.5 billion of net turnover in the Union in the financial year preceding the last, in two consecutive years.
Member States apply the CSDDD from 26 July 2029. It is a due diligence regime, separate from CSRD reporting.
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.
- EUR-LexDirective (EU) 2026/470 (Omnibus I) — Arts 2, 3, 5 and 6; recitals 26, 31 and 33
In force 18 March 2026. The €450m and 1,000-employee test; FY2027 for every undertaking that remains in scope; transposition by 19 March 2027 (Articles 1–3) and 26 July 2028 (Article 4).
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Arts 19a, 29a, 34 and 40a
The operative scope text, the value-chain cap in Art 19a(3), and the Article 40a test for non-EU groups.
- EUR-LexDirective (EU) 2025/794 (“stop the clock”)
Postponed the second and third waves by two years before Omnibus I rewrote scope.
- EUR-LexDirective (EU) 2022/2464 (CSRD) as adopted
The Directive Omnibus I amended. Read for its recitals; its original scope and wave dates are superseded.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 (revised ESRS), Article 3
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 applies from financial years beginning on or after 1 January 2027.
- EUR-LexRegulation (EU) 2020/852 (the Taxonomy Regulation), Article 8
Taxonomy disclosures bind undertakings subject to Articles 19a and 29a, and sit inside the CSRD assurance opinion.
- European CommissionStaff Working Document SWD(2026) 500 final
Omnibus I removes about 85% of companies from the original scope; 6,753 remain.
- European CommissionFeedback on sustainability reporting standards: the value chain cap, 6 May 2026
The Commission’s reading of what the cap does and does not reach.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Published 30 September 2026. Comply or explain against UK SRS for UKLR 6, 14, 15, 16 and 22, periods beginning on or after 1 January 2027.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶1.2, 1.7, 2.45, 3.6–3.7, 3.12, 3.14
The paragraph-level source for the UK column.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026 for voluntary use.
- IFRS Foundation / EFRAGESRS–ISSB Standards Interoperability Guidance, 2 May 2024 — Introduction and §1.1
The financial-materiality definition is aligned; the regimes are not, because ESRS add the impact lens.
Continue reading
Read next
CSRD reporting requirements for UK groups
Once in scope: the statement, the FY2026 choice, assurance and the timetable.
The Article 40a test
The non-EU route in depth, with worked examples and the draft standard.
UK SRS against ESRS
What a UK SRS report already gives you toward ESRS, and what it does not.