Answer 4 quick questions to check whether your company is in direct CSRD scope under the 2026 Omnibus thresholds — or facing indirect pressure from EU buyers.
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This tool applies the 2026 Omnibus CSRD thresholds under Directive 2022/2464/EU as proposed to be amended. It checks three pathways: direct mandatory scope (you must file a CSRD sustainability report), indirect supply-chain scope (your EU buyers need your ESG data for their own reports), and currently out-of-scope status with a forward-looking watch. The 2026 Omnibus raised the threshold significantly — most mid-market companies in scope under the original directive are now exempt from direct mandatory reporting.
Direct CSRD scope covers: EU large companies with more than 1,000 employees AND net turnover above €450 million (both conditions); EU-listed companies meeting the same thresholds; and non-EU parent groups with EU-generated net turnover above €450 million. The original 250-employee threshold was removed — approximately 80% of companies previously in scope are now exempt from mandatory reporting under the Omnibus proposal.
Even if you are not directly in CSRD scope, your EU customers who are in scope must disclose their Scope 3 supply-chain emissions under ESRS E1. They need your carbon data, energy data, and ESG metrics to complete their own mandatory reports. Companies that refuse to provide this data routinely find themselves replaced by suppliers who can. Indirect scope is commercially binding even when not legally mandatory. Use our Carbon Footprint Calculator for a free Scope 1, 2 and 3 baseline — the first thing any buyer data request asks for.
Largest EU companies in direct scope began reporting for financial year 2025 (published 2026). Mid-size in-scope companies begin for FY 2026 (published 2027). Non-EU companies with qualifying EU turnover begin for FY 2028 (published 2029). The What is CSRD? Complete Guide covers the full ESRS disclosure framework and double materiality methodology.
Last reviewed: October 2026. Reflects the 2026 Omnibus CSRD proposal thresholds. Member state transposition may vary.
Under the 2026 Omnibus thresholds, CSRD directly covers EU large companies with more than 1,000 employees AND net turnover above €450 million, EU-listed companies meeting those thresholds, and non-EU companies with EU-generated turnover above €450 million. The previous 250-employee threshold was removed, taking approximately 80% of companies out of mandatory direct scope.
The 2026 Omnibus raised the employee threshold from 250 to 1,000 and added a €450 million net turnover requirement. Both conditions must be met for direct scope. This removed most mid-market companies from mandatory CSRD scope compared to the original directive text.
Non-EU companies with EU-generated net turnover above €450 million, or with EU-listed securities, are in direct CSRD scope. More commonly, non-EU manufacturers face indirect scope: their EU customers need Scope 3 and supplier ESG data to complete their own mandatory CSRD reports under ESRS E1.
Indirect CSRD scope means you are not legally required to report, but your EU buyers are. They must collect emissions and ESG data from suppliers like you to fulfil their ESRS E1 Scope 3 obligations. Suppliers who cannot provide this data typically lose contracts or are replaced by compliant alternatives.
Under the Omnibus timeline: largest EU companies report for FY 2025 (published 2026); mid-size in-scope companies begin for FY 2026 (published 2027); non-EU companies with qualifying EU turnover begin for FY 2028 (published 2029).
Double materiality requires assessing sustainability from two directions: impact materiality (how your business affects environment and society) and financial materiality (how sustainability risks affect your finances). Both assessments are required to determine which ESRS disclosures apply to your company.
We offer CSRD readiness assessments, double materiality workshops, and full ESRS reporting support. TÜV-certified, €2.3M PI-insured, delivered in 90 days.
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