The Omnibus I amending directive (Directive (EU) 2026/470) entered into force on 18 March 2026. It cut the number of companies that must report under the CSRD sharply.
EU companies
A company (or group, on a consolidated basis) is in scope if it has more than 1,000 employees and more than €450 million net turnover. Both tests must be met.
Non-EU groups
A non-EU parent is in scope if it generates more than €450 million turnover in the EU in each of the last two financial years and has an EU subsidiary or branch with turnover above €200 million.
Who dropped out
- Most former "wave 2" companies with 250 to 1,000 employees.
- Listed SMEs (the old "wave 3").
- Member states may also exempt wave 1 companies that now fall below the new thresholds for financial years 2026 and 2027.
When the first reports are due
Companies that remain in scope and were not in wave 1 report for financial year 2027, in 2028, following the earlier "stop-the-clock" delay. Member states must transpose the CSRD changes by 19 March 2027, so check your national law for the final detail.
Out of scope does not mean off the hook
Large customers, banks and insurers will still ask for sustainability data. The Omnibus caps what reporting companies can demand from value-chain partners with fewer than 1,000 employees, and the voluntary standard gives smaller companies a ready-made format to answer them.
Last checked 12 October 2026. Educational content, not legal advice.