CSRD for Dummies

The Omnibus I Directive (EU 2026/470 – 24 February 2026) has significantly reduced the number of companies subject to CSRD reporting obligations.

The key question is simple: does your company still fall within scope?

The main remaining cases are:

• large EU companies;
• large EU consolidating groups;
• non-EU groups with significant EU presence.

1. Large EU companies

An EU company may be in scope if it exceeds BOTH of the following thresholds:

• more than 1,000 employees during the financial year
• more than €450 million net turnover

This test is applied on a standalone basis. Only the employees and turnover of the company itself are considered.

Net turnover includes revenues generated from goods and services, but excludes dividends, interest and capital gains.

Most holding companies therefore generally fall outside the scope of the standalone test.

2. EU consolidated groups

An EU parent company may be in scope if:

• it prepares consolidated accounts; and
• the consolidated group cumulatively exceeds:

• • 1,000 employees during the financial year
  • €450 million net turnover

The full consolidated group must be considered, including non-EU entities.

A group that does not prepare EU consolidated financial statements generally falls outside this test.

3. Non-EU groups with significant EU presence

A non-EU group may be in scope if:

• EU net turnover exceeds €450 million for two consecutive financial years; and
• it has, in the preceding financial year, either:

• • an EU subsidiary with more than €200 million net turnover; or
  • an EU branch exceeding that threshold.

In such case, the reporting obligation is carried by a designated EU entity.

4. Timeline

5. Important note

The practical application of the CSRD will also depend on the national implementation rules adopted in each EU Member State.

6. Legal references

• Directive 2013/34/EU (Accounting Directive)
• Directive (EU) 2022/2464 (CSRD)
• Directive (EU) 2026/470 (Omnibus I)
• Luxembourg Bill No. 8370 (not taking in consideration Omnibus I yet, though)

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