CSRD
Directive (EU) 2022/2464 — Corporate Sustainability Reporting Directive, as amended by Directive (EU) 2026/470
Topic : ESG disclosure · Level : Regional
Today
Omnibus I in force 18 Mar 2026: scope cut to >1,000 staff and >€450M turnover. Wave 2 reports on FY2027. Transpose by 19 Mar 2027.
Summary
The CSRD obliges large companies to publish audited sustainability reports under ESRS. Omnibus I (2026) limits scope to firms with over 1,000 employees and €450M turnover. First reports for the new scope cover FY2027.
Who is concerned
- Turnover
- > €450M net turnover (and >1,000 employees)
- Employees
- > 1,000 employees
- Listed company
- cotées et non cotées
- Sectors
- All sectors
- Triggering activities
- EU company/group above both thresholds
- Non-EU group with >€450M EU turnover
- EU subsidiary/branch with >€200M turnover
- Extraterritorial reach
- Yes
Non-EU groups with >€450M EU turnover report; suppliers abroad get data requests, capped at the voluntary standard if <1,000 staff
- Examples
- EU retailer, 3,000 staff, €2bn turnover
- Chinese group with EU sales >€450M and EU subsidiary
- German machinery maker, 1,500 staff, €600M
What the law requires
- Report sustainability matters under ESRS after a double-materiality assessment
- Publish the sustainability statement in the management report, tagged digitally
- Obtain limited assurance from an auditor or accredited provider
- Limit value-chain data requests to suppliers <1,000 staff to the voluntary standard
Penalties
Set by Member States (effective, proportionate, dissuasive). No EU-level fine amount.
What this changes for a supplier in China
Chinese suppliers to EU groups in scope receive ESRS data requests (Scope 3, workforce, pollution). If under 1,000 staff, they may refuse requests beyond the voluntary standard.
Expected evidence
- Scope 1-2 GHG inventory and product carbon data
- Workforce and health & safety indicators
- Environmental permits and pollution data
Tiers : Tier 1-2