This page reflects the scope agreed through the EU's Omnibus reforms as of mid-2026. Exact thresholds are still working through formal transposition into national law by EU member states (deadline: March 19, 2027) — confirm your company's specific position with a qualified adviser rather than relying solely on this summary.
The current threshold
Under the political agreement formalised as Directive (EU) 2026/470, mandatory CSRD reporting broadly applies to companies meeting both of the following:
- At least 1,000 employees
- At least €450 million in net turnover
This is a significant increase from the roughly 250-employee threshold originally set when CSRD was adopted in 2022 — see our CSRD Omnibus guide for how this changed.
Who's now excluded that wasn't before
Excluded entirely
Small and medium-sized listed companies, originally expected to be phased into CSRD scope, have been removed from mandatory scope altogether.
Excluded entirely
Also removed from mandatory scope under the agreed compromise.
Excluded, pending transposition
Companies that met the original ~250-employee threshold but fall short of the new 1,000-employee/€450m threshold are no longer in mandatory scope.
Non-EU companies
Non-EU companies fall within CSRD scope only if they generate at least €450 million in EU revenue — also raised considerably from earlier proposals. A non-EU company below that threshold, even a large one globally, generally has no CSRD reporting obligation.
If you already reported (Wave 1 companies)
Companies that reported for financial year 2024 continue reporting, but under the "quick-fix" delegated act, they don't need to add new disclosures arising from the simplified ESRS for financial years 2025 and 2026 — effectively a compliance pause while the revised standards are finalised.
Voluntary reporting is still an option
The European Commission's July 2026 delegated acts also established a new voluntary reporting standard — meaning companies now outside mandatory CSRD scope can still choose to report on a simplified, voluntary basis, which some companies pursue to satisfy investor or customer expectations even without a legal requirement to do so.
Frequently Asked Questions
What was the original CSRD employee threshold?
Roughly 250 employees, alongside turnover and balance sheet tests, when CSRD was first adopted in 2022. The Omnibus reforms raised this to approximately 1,000 employees and €450 million turnover.
Are listed SMEs completely out of CSRD scope now?
Under the agreed Omnibus compromise, yes — listed SMEs were removed from mandatory CSRD scope entirely, though they can still report voluntarily.
If I'm now out of scope, should I stop preparing?
That depends on your circumstances — some companies continue reporting voluntarily for investor or customer reasons, and thresholds could shift again as national transposition proceeds. Confirm your position with an adviser rather than assuming based on this summary alone.