CSRD for UK companies: four routes in
CSRD is not United Kingdom law and it never has been. It reaches UK companies by four routes only — and on 18 March 2026 Directive (EU) 2026/470 came into force and made three of them much narrower.
Three of the four are group-perimeter tests you cannot answer by looking at your own company. This page is the reconciliation: which door you are standing in, who actually files, and on which financial year.
Find which of the four doors you are in Four questions · a real “none of them” answer · nothing leaves your browserCSRD reaches a UK company by four routes, and no others
The Corporate Sustainability Reporting Directive is an EU instrument. It has no direct effect in the United Kingdom. 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.
Three of those four are decided at group level, not entity level.
That is the single most common reason a UK finance team reaches the wrong answer — they test the company in front of them, and the rule is testing the group above it.
Twenty-two miles of water.
And four ways across it.
Three of them are decided above your head
On 18 March 2026 the population was cut by roughly four fifths
Directive (EU) 2026/470 — Omnibus I — was dated 24 February 2026, published in the Official Journal on 26 February, and entered into force on the twentieth day after publication.
It is in force. It is not a proposal, it is not a consultation, and it is not “coming down the track”.
Three of the top eight results a UK finance director will find on this subject still describe the regime it replaced.
The turnover and headcount thresholds went up, the listed-SME wave was deleted outright, and the third-country threshold went from €150m to €450m.[1]
Directive (EU) 2026/470, Articles 1–3 and Article 6. Datapoint reductions from the Commission’s own adoption release of 3 July 2026 and Delegated Regulation C(2026) 5010 final.[2][3]
If you built a CSRD function and then fell out of scope
Roughly four fifths of the original CSRD population was removed from mandatory scope by an instrument that came into force after they had already hired, bought software and run a first double materiality assessment.
Nobody writes for that reader, so here it is plainly.
Why this page does not tell you how many companies are left
Figures of 4,700, 5,000, 6,000 and 6,750 all circulate and they disagree with each other.
The only defensible primary estimate is the Commission’s own staff working document, which puts the reduction at 75–82% and says 18–25% of undertakings remain in full scope.[4]
That document is dated February 2025 and was modelled against the proposal, not the final €450m text, so it is an estimate of a slightly different instrument.
A single current headcount would be a number we could not stand behind, so this page does not print one.
Which of the four doors is yours?
Four questions. It returns the route you came in by, the entity that carries the filing obligation, your first reporting financial year and publication year, and the one thing to do next.
“None of them” is a real answer and it is written out as fully as the others.
Logic from Directive 2013/34/EU Articles 19a, 29a and 40a as amended by Directive (EU) 2026/470.[1] Not legal advice — a group perimeter is a question for your own advisers.
€450m and 1,000 employees — not two out of three
The old CSRD test was two of three: 250 employees, €50m net turnover, €25m balance sheet. That test is gone.
What replaced it is conjunctive, and the word in the Directive is and.
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… Directive 2013/34/EU Article 19a(1), as amended by Directive (EU) 2026/470[1]
This is the test that decides Door one and Door three.
Door two is a different test entirely, with different numbers and no employee limb at all — which is why so many UK groups get it wrong.
There are 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.
Directive (EU) 2026/470 Article 5(1), both subparagraphs.[1] The Commission repeats the 19 March 2027 date in the explanatory memorandum to Delegated Regulation C(2026) 5010 final.[3]
For a UK group this matters in one practical way.
Your EU subsidiary’s obligation is whatever its own member state has enacted, on that member state’s timetable — so a Dutch subsidiary and an Irish one can be on different footings during 2026 and 2027.
Consolidated into an EU parent that is itself in scope
This is the commonest route and the least dramatic. Your UK entity does not acquire a filing obligation. It acquires a data obligation to somebody else’s filing.
Article 29a catches the parent undertaking of a group which, on a consolidated basis, exceeds €450m net turnover and 1,000 employees.
Where that parent is in the EU and reports at group level, every consolidated subsidiary is inside the statement — including subsidiaries outside the EU.
Who files, who signs, and who just sends spreadsheets
Across all four doors, the filing entity is rarely the UK entity. Getting this wrong is expensive in the other direction — teams build a reporting capability they were never going to use.
Door two is the one that surprises people.
The obligation sits on the third-country group, but it is discharged by an EU subsidiary or branch publishing the report — so a UK head office writes it and a Dublin or Amsterdam entity puts its name on the filing.
Article 40a — the door with no employee test
A UK-headquartered group can be caught by CSRD without a single EU-incorporated parent, purely on what it sells into the EU.
Two limbs, both required.
At group level, EU net turnover exceeding €450m in each of the last two consecutive financial years. And an EU subsidiary, or failing that an EU branch, with net turnover above €200m in the preceding financial year.
There is no headcount limb anywhere in Article 40a, and its absence is not an oversight — the reporting duty is different in kind, because the EU entity only publishes a report the group prepares.
Article 40a(1) of Directive 2013/34/EU, second, fourth and fifth subparagraphs, as replaced by Directive (EU) 2026/470 Article 2(13).[1] First reports cover financial years beginning on or after 1 January 2028, published 2029.
The two years that decide FY2028 are FY2026 and FY2027
This is the sentence a UK group with EU revenue should take away from the whole page.
Because Article 40a tests EU net turnover in each of the last two consecutive financial years, the qualifying window for a first FY2028 report is running right now.
You are inside the first of the two measured years.
Two consequences follow, and they point in opposite directions.
If your EU turnover is close to €450m, a single year above the line does not put you in scope — but it starts the clock, and the year you are in is the one that decides whether the second year matters.
And if you are above the line this year and expect to be next year, your FY2028 obligation is effectively already fixed, whatever happens after that.
Financial holding groups can be let out of Article 40a
Omnibus I added a derogation to Article 40a that we have not found on a single competing page, or on any other page of this site.
By way of derogation from the first and third subparagraphs, where the third-country undertaking is a financial holding undertaking whose subsidiary undertakings’ business models and operations are independent of one another, Member States shall ensure that the subsidiaries and the branches may decide not to publish and make accessible the sustainability report… Article 40a(1), new final subparagraph, inserted by Directive (EU) 2026/470 Article 2(13)(c)[1]
Recital 26 gives the reasoning: a level playing field for holding structures whose subsidiaries do not operate as one business.
Two cautions, and they are real.
It is a member-state option — “Member States shall ensure that the subsidiaries and the branches may decide” — so it lands in national law, and the national law is what you will be arguing from.
And “business models and operations are independent of one another” is not a defined term. If your group is a genuine financial holding company, this is worth putting in front of counsel in the relevant member state; it is not worth assuming.
Securities on an EU regulated market
A UK issuer admitted to trading on Euronext Paris, Euronext Amsterdam or the Frankfurt Stock Exchange is treated as an EU-listed undertaking for this purpose, wherever it is incorporated.
The size test is the same conjunctive pair as Door one: exceeding €450m net turnover and 1,000 employees, on a consolidated basis where the issuer is a parent.
Omnibus I rewrote the CSRD application article to say exactly that, in terms of issuers as defined in the Transparency Directive.[1]
What an EU customer can actually require of you
Every competitor page frames the value chain as “expect questionnaires”. Since 18 March 2026 there has been a statutory ceiling on those questionnaires, and a statutory right to decline what sits above it.
Almost no UK supplier knows it exists.
The mechanism, in the Directive’s own words
Three carve-outs, so nobody over-reads this
The cap bites only on requests made for the purpose of CSRD sustainability reporting. It expressly does not affect requests for other purposes, “including requests for the purpose of complying with Union requirements on undertakings to conduct a due diligence process”.
It does not stop anyone sharing information voluntarily, and it “imposes or implies” no obligation on any value-chain undertaking to provide sustainability information at all.
And it does not touch commercial due diligence, financing conditions, or a contractual term that has nothing to do with CSRD reporting.
The honest split on timing, because it matters
The right to decline is in force, in the Directive, since 18 March 2026.
The content of the ceiling — the voluntary standard that defines what “too much” means — was adopted on 3 July 2026 and is in the European Parliament and Council scrutiny period, which is two months and extendable by two more.
The Commission’s own wording is that the measures “will apply once the two-month scrutiny period… has ended”.[2]
Anyone telling you the datapoint ceiling is already in force is ahead of the Official Journal.
All quotations from Directive 2013/34/EU Articles 19a(3) and 29a(3) as amended by Directive (EU) 2026/470 Article 2, points (4)(b) and (5)(b); assurance interaction at Article 34(2a), inserted by point (12)(b).[1] The Commission’s value-chain-cap explanatory FAQ of 6 May 2026 covers the same ground and does not use the phrase “deemed to have complied”; the Directive does.[5]
The standards got much shorter on 3 July 2026
If a UK group is in scope through any of the first three doors, what it reports against is ESRS — and ESRS is not what it was a year ago.
The revision also removed anticipated-financial-effects requirements from ESRS E2 to E5 and kept them in reduced form in E1, and it simplified the materiality assessment.
EFRAG’s own cost analysis, quoted in the Commission’s memorandum, estimates savings averaging 34% of baseline costs over five years — 28% in 2027, 38% in 2028, settling at 33–36% from 2029 — rising to about 44% and €4.7bn cumulative over 2027–2031 once value-chain effects are counted.[3]
That analysis carries its own caveat in the source, and it belongs with the numbers: the estimates are “based on the proposed standards submitted by EFRAG and not the final delegated act adopted by the Commission”.
“CSRD S1” is not IFRS S1, and the difference is total
Two standard-setters numbered their standards S1 and S2 within two years of each other, about the same subject, for different purposes. Nobody disambiguates it, and people search for it.
So a board paper that says “we are doing S1 and S2” is ambiguous until somebody names the regime.
Under CSRD that sentence means workforce and value-chain workers. Under UK SRS it means general requirements and climate.
They do not overlap at all.
UK SRS does not discharge CSRD, and CSRD does not discharge UK SRS
There is no equivalence decision between the two regimes. Not a pending one, not a partial one — none.
Doing one well does not satisfy the other, and a UK company caught by both is caught by both.
The practical version of this is the only sentence a group finance director needs.
Share the data, separate the assessments.
CSRD vs UK SRS — the comparison, current to August 2026
Same shared IFRS ancestry, materially different scope, materiality and timing.
The row that does the most work is the second one.
The EU side is settled law with dates in it. The UK side is a published voluntary standard plus a regulator’s proposal, and until the FCA publishes its Policy Statement in autumn 2026 there is no UK mandate at all.
Any comparison that prints “2027” on both sides in the same weight is misleading you.
Two lenses, and only the overlap is shared work
UK SRS asks what could affect enterprise value. 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. It is a different question, with different evidence behind it.
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.
What differs is what each regime does with them.
The practical consequence is that a group caught by both does not need two inventories.
It needs one inventory with enough granularity to answer the more demanding of the two questions, and a control environment that can evidence it to an assurance provider.
Which reporting year bites first, for your year-end
Reporting obligations attach to financial years, not calendar years, and most published timelines quietly assume a 31 December year-end.
If yours is March, June or September, the year that bites is probably not the one you think.
EU dates from Directive (EU) 2026/470 and Delegated Regulation C(2026) 5010 final.[1][3] UK dates from FCA CP26/5, which is a consultation proposal; the Policy Statement is expected autumn 2026 and nothing on the UK side is settled until it publishes.[6]
Four things on this page could change, and here is when
A reference page that pretends the ground is still is not a reference page.
Four doors, and three of them are somebody else’s filing.
The fourth is the one you can answer today.
CSRD is not your law, but it can still be your obligation — and the only way to know is to test the group, not the company.
Six things worth remembering
If your group sells more than €450m into the EU, the standard you will report against is still in consultation — and it closes on 31 October 2026.
See what ESRS‑40a will require of you Or start on the UK side insteadFour ways UK companies get caught by CSRD
CSRD scoping is a group-perimeter exercise, not an entity-level test.
Even if a UK company is not directly in scope, it can still be drawn in via consolidation, Article 40a, an EU listing, or value-chain requests.
Strategic context and regulatory landscape
EU CSRD and UK SRS are parallel developments in sustainability reporting, both building on IFRS Sustainability Standards foundations.
ESRS applies to EU companies and to non-EU companies with significant EU operations; UK SRS is aimed at UK-listed companies under FCA CP26/5.
CSRD implementation began in January 2024 for the first wave, while UK SRS proposed mandatory implementation from January 2027 remains subject to the FCA Policy Statement expected in autumn 2026.
Planning for both means running one double materiality assessment, one data scope, and where possible one reporting architecture with coordinated assurance strategies.
CSRD and UK SRS at a glance
The ~515 figure is the population of a proposed regime, not a current one.
On the FCA’s own CP26/5 analysis roughly 600 companies are affected, of which about 515 would be required to comply.
Regulatory coverage and company impact
Implementation implications for UK companies
UK groups with EU market presence need a dual-compliance strategy rather than two programmes.
The options are an integrated architecture serving both frameworks, jurisdiction-specific reports, or voluntary harmonisation above both minimums, supported by systematic implementation planning.
Data architecture is where the cost actually sits, because ESRS asks for a broader ESG scope than UK SRS S2’s climate focus.
Integrated assurance strategies reduce duplicated effort through coordinated practitioner engagement, particularly for GHG emissions reporting where both regimes read the same underlying inventory.
Four dual-compliance positions
Four practical steps for UK companies
CSRD UK — when EU CSRD applies to UK companies
CSRD UK: the Corporate Sustainability Reporting Directive is an EU instrument and does not have direct effect in the United Kingdom.
A purely UK-domiciled company with no EU subsidiaries, branches, listed securities or EU customer requests is not required to file an ESRS-aligned sustainability statement.
UK-domiciled reporting is instead addressed by the UK SRS S1 and S2 standards, which are voluntary today and would become mandatory for part of the listed population only if the FCA confirms CP26/5.
Where CSRD UK exposure does bite it is through one of the four routes mapped in the four ways UK companies get caught.
CSRD compliance consulting UK — what advisers actually do
UK-facing CSRD engagements usually open with a group-perimeter exercise: which UK entities consolidate into an in-scope EU parent, whether the wider group crosses Article 40a, and which EU subsidiary or branch would publish the resulting report.
From there the work is a double materiality assessment, an ESRS gap analysis against existing UK SRS and SECR data, and the control design needed to sustain limited assurance.
CSRD compliance software UK — what UK groups actually buy
CSRD compliance software UK is the market serving UK groups caught through one of the four routes above.
Most enterprise carbon and ESG platforms now ship a CSRD module covering the ESRS datapoints, a double materiality workflow, and ESRS digital tagging for the filing.
Two buying notes specific to the post-Omnibus position.
The mandatory datapoint set fell by 61% on 3 July 2026, so a platform still marketing itself on the size of its 2023 datapoint library is selling you the wrong thing.
And a UK group caught by both regimes should buy once: the Scope 1, 2 and 3 inventory, the governance log and the transition plan serve UK SRS S2 and ESRS E1 alike, and only the ESRS-specific topical standards sit outside that overlap.
Frequently asked questions
Answers reflect Directive (EU) 2026/470 as in force on 18 March 2026, the revised ESRS adopted 3 July 2026, and FCA CP26/5 as it stood on 8 August 2026.