# CSRD Reference - Verified Facts and Sources (current as of mid-2026) Companion to SKILL.md. Long tables and the full source list live here so the skill file stays lean. Everything below was web-verified in June 2026. Each statement is tagged SETTLED (final law in force) or PENDING (proposal / delegated act not yet adopted / national transposition outstanding). ASCII only. Write "EUR 450m", not the euro glyph. No em-dashes. --- ## 1. The three "Omnibus" things - never conflate them | # | Name | Legal status | What it did | |---|------|--------------|-------------| | 1 | Omnibus I **proposal** | Commission proposal, 26 Feb 2025 | Proposed simplifying CSRD, CSDDD, EU Taxonomy, CBAM. A proposal, not law. | | 2 | **"Stop-the-clock"** Directive (EU) **2025/794** | SETTLED. OJ 16 Apr 2025; in force 17 Apr 2025; transposition by 31 Dec 2025 | Delayed Waves 2 and 3 by two years and delayed CSDDD. Timing only; no threshold change. | | 3 | **Final Omnibus I** Directive (EU) **2026/470** | SETTLED. Council 24 Feb 2026; OJ 26 Feb 2026; in force 18 Mar 2026 | The substantive change: new scope thresholds, listed SMEs out, non-EU thresholds raised, value-chain cap, assurance ceiling fixed at limited. | Always say which one you mean. --- ## 2. Scope thresholds ### Current (SETTLED - Directive (EU) 2026/470, in force 18 Mar 2026) An EU undertaking is in scope only if it exceeds **BOTH**: - more than **1,000 employees** (average over the financial year), **AND** - net turnover of more than **EUR 450 million**, assessed at individual or group level. This is a cumulative **AND** test on two metrics. The old balance-sheet criterion is **dropped** from the in/out gate. - **Listed SMEs:** removed from mandatory scope. They may report voluntarily using **VSME**. - **Non-EU (third-country) parent:** in scope if it generates more than **EUR 450m net turnover in the EU** (was EUR 150m) for two consecutive years, **AND** has either an EU subsidiary that is a large undertaking, or an EU branch with more than **EUR 200m net turnover** (was EUR 40m). - **Scope reduction:** Commission estimates about **80%** of previously-covered companies are removed (from roughly 50,000 to roughly 5,000). - **Value-chain cap:** an in-scope company may not demand sustainability data beyond the **VSME** standard from a value-chain partner with fewer than 1,000 employees ("protected undertaking" right to refuse). ### Old test (SUPERSEDED - original 2022 CSRD) Two-of-three: more than 250 employees / more than EUR 50m turnover / more than EUR 25m balance-sheet total. Plus large PIEs with more than 500 employees (the old NFRD population), listed SMEs, and non-EU parents at the EUR 150m / EUR 40m thresholds. Use only to explain what changed. --- ## 3. Timeline ### Current state (SETTLED unless noted) | Group | Status now | First FY | First report | |-------|-----------|----------|--------------| | Wave 1 (former 500+ PIEs) still above new thresholds | In scope, continuing | FY2024 already reported | continuing | | Wave 1 now below new thresholds | Out of scope. **Optional** Member-State transition exemption for FY2025 and FY2026; mandatory exit FY2027 (PENDING per country) | n/a | n/a | | Newly-defined scope (1,000+ emp AND 450m+ turnover) | In scope | **FY2027** (years starting on/after 1 Jan 2027) | **2028** | | Former Wave 2 / Wave 3 below threshold | Out of mandatory scope; voluntary VSME | n/a | n/a | | Non-EU groups meeting new higher thresholds | In scope | **FY2028** | **2029** | "First mandatory reports in 2028" describes the **newly-defined** in-scope set, not large companies already reporting since FY2024. ### Key dates - CSRD transposition deadline (Omnibus): **19 March 2027** (CSDDD parts: 26 July 2028). - Original CSRD = Directive (EU) **2022/2464**, in force 5 Jan 2023; replaced NFRD (2014/95/EU); amends Accounting Directive 2013/34/EU. --- ## 4. ESRS - the 12 standards First set adopted as Delegated Regulation (EU) **2023/2772** (applicable FY2024). | Code | Slug | Pillar | What it covers | |------|------|--------|----------------| | ESRS 1 | esrs-1-general-requirements | Cross-cutting | Architecture and concepts (double materiality, value chain, time horizons). No disclosures itself. | | ESRS 2 | esrs-2-general-disclosures | Cross-cutting | Mandatory baseline: governance, strategy, IRO management, metrics and targets. Applies to ALL reporters regardless of materiality. | | ESRS E1 | e1-climate-change | Environment | GHG emissions (Scope 1/2/3), transition plan, energy, climate risk. | | ESRS E2 | e2-pollution | Environment | Air, water, soil pollution; substances of concern. | | ESRS E3 | e3-water-marine-resources | Environment | Water consumption, withdrawals, marine impacts. | | ESRS E4 | e4-biodiversity-ecosystems | Environment | Impacts and dependencies on nature. | | ESRS E5 | e5-circular-economy | Environment | Resource inflows/outflows, waste, circularity. | | ESRS S1 | s1-own-workforce | Social | Working conditions, pay, diversity, health and safety. | | ESRS S2 | s2-value-chain-workers | Social | Labour conditions in the value chain. | | ESRS S3 | s3-affected-communities | Social | Impacts on local and indigenous communities. | | ESRS S4 | s4-consumers-end-users | Social | Product safety, data privacy, inclusion. | | ESRS G1 | g1-business-conduct | Governance | Anti-corruption, lobbying, payment practices, whistleblowing. | **ESRS 2 is always mandatory.** Topical standards (E1-E5, S1-S4, G1) apply only where the topic is material under the double-materiality assessment. ### ESRS revision ("ESRS 2.0") - PENDING - 3 Dec 2025: EFRAG delivered technical advice on simplified ESRS. - 6 May 2026: Commission published the **draft revised ESRS delegated act** for a four-week consultation; feedback closed **3 June 2026**. - Adoption target: within six months of Omnibus entry into force, i.e. by about **17 Sep 2026** (some advisers expect adoption as early as June/July 2026). Not yet adopted as of June 2026. - Application: revised ESRS apply from **FY2027**; companies already reporting may **voluntarily** apply the simplified set for FY2026. - Datapoint cut: mandatory datapoints reduced by **more than 60%**, total datapoints by **more than 70%** (EFRAG draft removed 489 previously-mandatory datapoints and all voluntary datapoints). Exact figure varies by source. - **Sector-specific ESRS:** effectively dropped / abandoned under the simplification drive. // VERIFY against the final delegated act when adopted. - **VSME** voluntary SME standard: Commission Recommendation (late 2025); delegated act expected around mid-2026 (PENDING). --- ## 5. Double materiality Report a sustainability matter if it is material under **either** lens: - **Impact materiality (inside-out):** the company's actual or potential, positive or negative impacts on people and the environment, over short/medium/long term, including through the upstream and downstream value chain. - **Financial materiality (outside-in):** sustainability matters that affect the company's cash flows, development, performance, position, cost of capital or access to finance. Either lens is enough. The Double Materiality Assessment (DMA) drives which topical ESRS apply. Double materiality survives the Omnibus; the revision aims to make the DMA simpler and less prescriptive, not to remove it. --- ## 6. Assurance and digital tagging - **Limited assurance** required on the sustainability statement (statutory auditor or, where a Member State allows, an independent assurance services provider). SETTLED. - **Reasonable assurance is OFF the table.** The Omnibus removed the planned escalation from limited to reasonable. Limited is now the permanent ceiling. SETTLED. - EU-wide limited-assurance standard postponed to about **1 July 2027** (expected to align with **ISSA 5000**). Until then national standards apply. PENDING. - **Digital:** sustainability statement in **XHTML** + **Inline XBRL** under **ESEF**; ESRS XBRL taxonomy by EFRAG; ESMA embeds it in technical standards; feeds the **European Single Access Point (ESAP)**. Exact mandatory-tagging phasing is being aligned with the revised ESRS. // VERIFY current ESMA RTS status. --- ## 7. Linked frameworks - **EU Taxonomy** (Reg. (EU) 2020/852): Article 8 KPIs - % of turnover, capex, opex aligned with environmentally sustainable activities. 6 environmental objectives; eligibility (activity on the list) vs alignment (also meets technical screening criteria + DNSH + minimum safeguards). Omnibus simplified Taxonomy reporting too. - **GHG Protocol** (ESRS E1): Scope 1 (direct), Scope 2 (purchased energy; location-based vs market-based), Scope 3 (15 value-chain categories - 8 upstream, 7 downstream). Scope 3 is the most demanding. - **ISSB IFRS S1/S2:** global baseline, **single** (financial) materiality. EFRAG-ISSB interoperability guidance aligns climate metrics. ESRS XBRL taxonomy built to be compatible. - **TCFD:** absorbed into ESRS E1 and ISSB S2; TCFD wound down, monitoring moved to ISSB. - **GRI:** impact-oriented; high interoperability with ESRS impact disclosures. --- ## 8. Penalties CSRD is a directive, so penalties are set by each Member State and must be "effective, proportionate and dissuasive." Variation is large: - Public-procurement exclusion in several states. - Administrative fines; commentary references up to about 5% of global annual turnover in some regimes. - France: fines and, for obstructing assurance, criminal sanctions (fines and up to 5 years imprisonment). Czech Republic: fines up to 3% of total assets for failure to file. - Director / civil / administrative liability in some transpositions. Always check the specific Member State. Transposition of the Omnibus thresholds is outstanding in most states until 19 March 2027 (PENDING). --- ## 9. Sources (web-verified June 2026) Primary / official: - EUR-Lex, Directive (EU) 2022/2464 (CSRD): https://eur-lex.europa.eu/eli/dir/2022/2464/oj/eng - Council of the EU press release, 24 Feb 2026 (final sign-off): https://www.consilium.europa.eu/en/press/press-releases/2026/02/24/council-signs-off-simplification-of-sustainability-reporting-and-due-diligence-requirements-to-boost-eu-competitiveness/ - European Commission, Corporate sustainability reporting: https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en - European Parliament Legislative Train, Omnibus I: https://www.europarl.europa.eu/legislative-train/package-simplification-business/file-first-omnibus-package-on-sustainability-proposal-amending-csrd-and-csddd - EFRAG, technical advice on simplified ESRS: https://www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission Directive (EU) 2026/470 finalisation and scope: - Garrigues, Publication of Directive (EU) 2026/470: https://www.garrigues.com/en_GB/new/publication-directive-eu-2026470-simplifying-corporate-sustainability-reporting-csrd-and-due - DLA Piper, EU Council approves Omnibus I Directive: https://knowledge.dlapiper.com/dlapiperknowledge/globalemploymentlatestdevelopments/2026/eu-council-approves-omnibus-i-directive - Covington, Omnibus published in OJ - transposition, delegated acts, guidelines next: https://www.cov.com/en/news-and-insights/insights/2026/02/eu-csddd-csrd-omnibus-published-in-official-journal-transposition-delegated-acts-and-guidelines-are-next - PwC Viewpoint, "Omnibus" directive finalised: https://viewpoint.pwc.com/gx/en/pwc/in-briefs/ib_int202527.html - Norton Rose Fulbright, EU adopts Omnibus Directive amending CSRD and CS3D: https://www.nortonrosefulbright.com/en/knowledge/publications/1679488b/european-parliament-votes-to-adopt-omnibus-proposal-amending-csrd-and-cs3d - Latham & Watkins, EU Sustainability Omnibus published in the Official Journal: https://www.lw.com/en/insights/eu-sustainability-omnibus-published-in-the-official-journal Stop-the-clock: - Sidley, EU adopts Stop-the-Clock Directive and begins ESRS simplification: https://www.sidley.com/en/insights/newsupdates/2025/04/eu-omnibus-package-eu-adopts-stop-the-clock-directive-and-begins-esrs-simplification-process Revised ESRS / assurance / VSME: - Latham & Watkins, European Commission publishes revised ESRS for consultation: https://www.lw.com/en/insights/european-commission-publishes-revised-esrs-for-consultation - Covington, European Commission publishes "ESRS 2.0" for public consultation: https://www.cov.com/en/news-and-insights/insights/2026/05/european-commission-publishes-esrs-2-0-for-public-consultation-draft-closely-follows-efrags-technical-advice-with-additional-simplifications-for-companies - Morrison Foerster, EC proposes revised ESRS and new voluntary standard: https://www.mofo.com/resources/insights/260513-european-commission-proposes-revised-esrs - Deloitte, EU Sustainability Reporting - Omnibus updates (14 Jan 2026): https://dart.deloitte.com/USDART/home/publications/deloitte/heads-up/2026/eu-sustainability-reporting-omnibus-esrs-updates - BDO, CSRD post-Omnibus revised scope and requirements: https://www.bdo.com/insights/sustainability-and-esg/csrd-post-omnibus-revised-scope-and-requirements Double materiality: - Deloitte, Unpacking the Double Materiality Assessment: https://dart.deloitte.com/USDART/home/publications/deloitte/heads-up/2024/csrd-esrs-double-materiality-assessment Retrieved: June 2026.