CSRD report 2026: who must report and when
Since March 2026 the CSRD only applies to very large companies. This page covers the scope after the Omnibus package, the deadlines, what a report contains and what suppliers can push back on, as of October 2026.
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Directive (EU) 2026/470· Revised ESRS· As of October 2026
Who must report after the Omnibus package
Directive (EU) 2026/470 has been in force since 18 March 2026. It narrows the CSRD to companies that exceed both thresholds, on a consolidated basis.
EU companies and groups
More than 1,000 employees and more than €450 million net turnover. Newly in scope for financial years starting on or after 1 January 2027, first report in 2028.
First-wave companies
Companies that already reported but stay below the new thresholds drop out. Member states may exempt them for financial years 2025 and 2026 already.
Non-EU groups
Groups from outside the EU with more than €450 million net turnover in the EU and a large EU subsidiary or branch.
Listed SMEs
Out of scope. The earlier postponement by the “stop-the-clock” directive (EU) 2025/794 is overtaken for them.
Member states must transpose the amendments by 19 March 2027. In Germany the CSRD transposition act was not yet adopted as of October 2026; companies already reporting continue under the existing rules of the German Commercial Code until then.
Does the CSRD apply to your company?
Three questions, based on the thresholds of Directive (EU) 2026/470. Use group figures if you belong to a group.
The check applies the EU thresholds. National transposition can add details; in Germany the transposition act was not yet adopted as of October 2026. Not legal advice, but a fast first answer.
CSRD deadlines at a glance
| Who | Financial year | Report |
|---|---|---|
| Companies with >1,000 employees and >€450m turnover | from 2027 | from 2028 |
| First-wave companies below the new thresholds | drop out from 2027; member states may exempt 2025 and 2026 | none |
| Listed SMEs | not in scope | none |
| Companies below the thresholds | voluntary (VSME) | on request |
What a CSRD report contains
The report is part of the management report and follows the European Sustainability Reporting Standards (ESRS).
Revised ESRS
Delegated Regulation (EU) 2026/1563 applies to financial years from 2027. For financial year 2026, reporting companies may still use the old ESRS, the old ESRS with reliefs, or the new ones.
Double materiality
Which topics are reported is decided by the double materiality assessment: a topic is material if it is material from the impact or the financial perspective.
Assurance
The report needs external limited assurance. The planned move to reasonable assurance was removed by the Omnibus package.
Climate
ESRS E1 covers climate change, including greenhouse gas emissions across scopes 1 to 3. Physical climate risks are reported where material; there is no separate ISO obligation.
What suppliers can push back on
Reporting companies may only ask suppliers with up to 1,000 employees for information within the scope of the voluntary standard, Delegated Regulation (EU) 2026/1560. A 40-page ESRS questionnaire sent to a mid-sized supplier is no longer something it has to fill in completely.
In practice that makes a VSME report the best answer to customer requests: one document, recognised by the regulation, instead of a new questionnaire every quarter.
Less obligation does not mean fewer questions
The Omnibus package is not a reduction of bureaucracy for me, but a deletion of data in instalments. Climate and biodiversity data that is never collected does not show up in any bank’s risk model either. Lenders will close that gap themselves, with their own questionnaires to you.
Whoever sets up their data once along the voluntary standard answers those questionnaires from one source instead of searching again every year.
When you need an answer for your company
Whether you are in scope, need a VSME report for customers, or want to prepare the double materiality assessment: tell me where you stand.
Frequently asked questions about the CSRD
Who must report under the CSRD?
After Directive (EU) 2026/470, companies and groups with more than 1,000 employees and more than €450 million net turnover, for financial years from 2027. Listed SMEs are no longer in scope.
What are the CSRD reporting deadlines?
Newly in-scope companies report for financial year 2027, publishing in 2028. First-wave companies below the new thresholds drop out from 2027, and member states may exempt them for 2025 and 2026.
Does the CSRD report need an audit?
Yes, limited assurance by an external auditor. The planned step to reasonable assurance has been removed.
Do SMEs need a CSRD report?
No. They can report voluntarily under the VSME standard, and reporting customers may not ask them for more than that standard covers.
What are the principles of sustainability reporting?
There is no official list of seven. The GRI Standards name eight reporting principles: accuracy, balance, clarity, comparability, completeness, sustainability context, timeliness and verifiability. The ESRS rely on qualitative characteristics of information instead, such as relevance, faithful representation, comparability, verifiability and understandability.
Has Germany transposed the CSRD?
Not as of October 2026. A government bill was amended in March 2026 to reflect the Omnibus package; until the act applies, companies already reporting follow the existing rules of the German Commercial Code.
What does the CSRD mean for the value chain?
Reporting companies need data from suppliers, but may only request information within the voluntary standard from suppliers with up to 1,000 employees. It is the rare case where a regulation actually limits the number of questionnaires.
Are you in scope?
Run the check or write to me. I will tell you what applies to you and what you can safely leave aside.