CSRD After the Omnibus: Who's Still In Scope?

The EU cut CSRD scope by ~80% in December 2025. New thresholds, revised timelines, simplified ESRS. Here's the current state as of March 2026.

Updated: March 2026 Sources: EU Directive 2026/470, EFRAG, Deloitte, BDO Reading time: 10 min

Status (March 2026): Directive 2026/470 was published in the EU Official Journal on February 26, 2026, and enters into force March 19, 2026. Member states must transpose CSRD provisions by March 19, 2027. The revised ESRS goes into final public consultation Q1/Q2 2026.

On this page

What Changed New Scope Thresholds Revised Timeline Simplified ESRS US Companies: Are You Affected? What to Do Now

What Changed: Omnibus I in 60 Seconds

In February 2025, the European Commission proposed the "Omnibus Simplification Package" to reduce the burden of CSRD and CSDDD on European businesses. After negotiation, the European Parliament approved the final text in December 2025. Key changes:

Scope reduced ~80%. Only companies with 1,000+ employees AND EUR 450M+ turnover are now in scope. Previously: 250+ employees OR EUR 40M+ turnover.

Listed SMEs removed. Previously required to report from FY 2026. Now entirely out of scope.

ESRS simplified. Mandatory datapoints reduced by 61% (from ~1,100 to ~430). Voluntary disclosures eliminated entirely.

Timeline pushed back. "Stop the Clock" directive gives Wave 2 and Wave 3 companies a 2-year delay. First reporting for newly scoped companies: FY 2027 (reports published 2028).

Value chain cap introduced. Companies with fewer than 1,000 employees in your value chain can legally refuse information requests beyond what's specified in a voluntary SME standard.

New Scope Thresholds

The table below compares the original CSRD thresholds with the revised Omnibus thresholds.

Criterion	Original CSRD	After Omnibus	Impact
Employees	250+	1,000+	Major change
Net turnover	EUR 40M+	EUR 450M+	Major change
Total assets	EUR 20M+	Removed as standalone trigger	Simplified
Listed SMEs	In scope (FY 2026)	Out of scope entirely	Removed
Non-EU parent companies	EUR 150M+ EU turnover	EUR 450M+ EU turnover	Narrowed
Both criteria required?	Any two of three	Both employees AND turnover	Stricter

Quick test: If your company has fewer than 1,000 employees OR less than EUR 450M in annual turnover, you are likely out of the revised CSRD scope. Check with your legal advisor for jurisdiction-specific implementation.

Revised Reporting Timeline

FY 2024

Wave 1: Large EU public-interest entities already under NFRD. ~500 companies. Reported in 2025. Still in scope.

FY 2025-26

Wave 2 (delayed): Large EU companies meeting old thresholds. "Stop the Clock" pushed them to FY 2027. Member states may further exempt companies below new thresholds.

FY 2027

New effective start: Companies meeting the revised 1,000 employee / EUR 450M thresholds report for the first time. Reports published in 2028. Uses simplified ESRS.

FY 2028

Non-EU companies: Non-EU parent entities with EUR 450M+ EU turnover and qualifying EU subsidiaries/branches must report.

Simplified ESRS: What's Different

EFRAG is revising the European Sustainability Reporting Standards to align with the simplified scope. The current draft (entering public consultation Q1/Q2 2026) includes these changes:

Change	Original ESRS	Revised ESRS (Draft)
Mandatory datapoints	~1,100	~430 (61% reduction)
Voluntary disclosures	Included	Eliminated entirely
Climate (ESRS E1)	Mandatory for all in-scope	Subject to materiality assessment
Scope 3 reporting	Required for material categories	Phase-in extended; "available without undue cost or effort" qualifier
Biodiversity (ESRS E4)	Required if material	Phase-in extended through 2026 for Wave 1
Materiality approach	Some standards mandatory regardless	100% subject to materiality — including Climate

US Companies: Are You Affected?

US companies can be caught by CSRD in two ways:

1. Listed on an EU-regulated market

If your company lists securities on an EU exchange and meets both thresholds (1,000+ employees, EUR 50M+ revenue OR EUR 25M+ assets) for two consecutive years, you report under full ESRS starting FY 2027.

2. Significant EU operations

Non-EU parent companies with EUR 450M+ net turnover in the EU AND an EU subsidiary with EUR 200M+ turnover (or EU branch with EUR 50M+) must report starting FY 2028. Reports due in 2029.

California SB 253 is separate. The CSRD Omnibus does not affect California's climate disclosure requirements. SB 253 still requires Scope 1/2 reporting for companies with $1B+ revenue doing business in California (FY 2026), with Scope 3 following in FY 2027. SB 261 enforcement is currently paused.

What Should You Do Now?

If you're clearly in scope (1,000+ employees, EUR 450M+ turnover)

Prepare for FY 2027 reporting. Complete your double materiality assessment. Build your data collection framework. The timeline is tight — reports are due in 2028 and you need baseline data covering all of FY 2027.

If you're now out of scope

You may still face pressure from customers, investors, and lenders who are in scope and need data from their value chain. The value chain cap limits what they can demand, but market expectations often exceed regulatory minimums. Consider voluntary reporting aligned with the VSME standard.

If you're a mid-market US company

Check your California exposure (SB 253), investor requirements (CDP), and customer requests. The CSRD may not apply to you directly, but your European customers' Scope 3 requirements may pull you into the ecosystem regardless.

Not sure where you stand?

Emberglow runs a free regulatory gap assessment across CSRD, SB 253, ISSB, and CDP. 30 minutes. No commitment.

Book a Free Diagnostic