- Since the Omnibus package (Directive (EU) 2026/470, in force on 18 March 2026), the CSRD applies to companies with more than 1,000 employees and over €450M in net turnover.
- This scope is significantly narrower than the directive's initial version.
- It should not be confused with the accounting definition of a "large company" (250 employees / €50M turnover / €25M balance sheet, 2 of 3 criteria).
- Companies below these thresholds are out of the mandatory scope and can use the voluntary VSME standard.
Understanding the logic of the CSRD threshold
The CSRD requires certain European companies to publish sustainability information. Since the adoption of the Omnibus package, the scope has been clearly narrowed: the trigger now relies on headcount and net turnover. Identifying whether you exceed these thresholds is the first step of a compliant ESG strategy. For the full scope and content, see the CSRD criteria.
The CSRD scope thresholds after the Omnibus
The Omnibus package was adopted and enacted through Directive (EU) 2026/470, published in the Official Journal of the European Union on 26 February 2026 and in force on 18 March 2026. It significantly raises the CSRD scope thresholds:
| Criterion | CSRD threshold (post-Omnibus) |
|---|---|
| Headcount | more than 1,000 employees |
| Net annual turnover | over €450M |
A company exceeding these thresholds is in scope and must publish an ESRS-compliant sustainability report subject to external audit.
"Large company": an accounting definition to distinguish
The CSRD scope should not be confused with the accounting definition of a "large company", based on three criteria (2 of 3 are enough):
| Accounting criterion | Threshold |
|---|---|
| Average annual headcount | 250 employees |
| Net turnover | €50M |
| Balance-sheet total | €25M |
These thresholds (which replaced the former €40M turnover and €20M balance sheet) serve as an accounting reference but, since the Omnibus, are no longer the trigger of the CSRD obligation.
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SMEs and out-of-scope companies: the role of VSME
Companies below the scope thresholds are not subject to the legal obligation. They can, however, voluntarily use the VSME standard developed by EFRAG to answer the ESG requests of their clients, bankers or business partners, without the audit constraints of the CSRD.
Non-EU companies and groups
Companies established outside the European Union but with significant activity in the EU may also be concerned, under specific thresholds. For groups, assessment is made at both entity and consolidated levels: a subsidiary can be exempt from its own report if the parent publishes a consolidated CSRD report covering its activities.
Companies near the thresholds: how to anticipate
Companies whose growth brings them closer to the thresholds should prepare early: clear governance (board-level sustainability oversight), ESG data centralized on a dedicated platform, a double materiality analysis to select the right indicators, and a two-year timeline (measurement in year 1, a test report in year 2 before formal audit).
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CSRD thresholds: key takeaways
| Key point | Explanation |
|---|---|
| CSRD thresholds (post-Omnibus) | More than 1,000 employees and over €450M net turnover |
| Legal basis | Directive (EU) 2026/470, in force on 18 March 2026 |
| Not to be confused with | Accounting definition of a "large company": 250 emp. / €50M / €25M, 2 of 3 |
| Below the thresholds | Out of mandatory scope; voluntary VSME standard |
| Groups and non-EU | Consolidated reporting possible; significant EU activity potentially concerned |
