Does CSRD still apply to your company?

Only if you exceed both halves of the test that applies to you. For an EU undertaking that means more than 1,000 employees and more than €450 million of net turnover. Exceeding one alone is not enough. Omnibus I, adopted in February 2026, removed roughly 80 percent of the companies the original directive captured.

EU undertakings are tested on more than 1,000 employees on average during the financial year and net turnover above €450 million. Non-EU groups are tested differently: more than €450 million of turnover generated in the EU, together with an EU subsidiary or branch above €200 million.

The revised requirements apply to financial years starting on or after 1 January 2027, so the first report under this regime is published in 2028.

Yes, through a separate third-country test. A non-EU group is caught when it generates more than €450 million of net turnover in the EU in each of the last two consecutive financial years and has an EU subsidiary or branch generating more than €200 million. A qualifying subsidiary must itself be a large EU undertaking. Applying the EU headcount and turnover test to a non-EU group gives the wrong answer in both directions.

On 3 July 2026 the Commission adopted the delegated act containing the revised ESRS (2026). It cuts mandatory datapoints by around 61 percent and total datapoints by more than 70 percent, with per-company reporting costs expected to fall by over 30 percent. It applies to financial years beginning on or after 1 January 2027, with optional early application for FY2026 and FY2027, and is subject to scrutiny by the Parliament and the Council.