CSRD consultancy
Most UK companies told they were in scope no longer are. Check first.
What Omnibus I actually changed.
Directive (EU) 2026/470 came into force on 18 March 2026 and reset who has to report.
It did not soften the regime at the edges; it removed most of the population from it.
The scope test is now a single cumulative test. Both limbs, or you are out.
The change that matters to a UK reader
An undertaking is in scope only if it exceeds both €450 million net turnover and 1,000 employees.
Everything else in this page follows from that one sentence, and from the date it starts to bite.
Does CSRD reach you at all?
The United Kingdom is outside the CSRD, so a UK company is never in scope by being British.
Why the answer is usually no
Exposure arises only through an EU undertaking of your own, securities on an EU regulated market, or the third-country regime.
Each of those has a threshold, and each threshold rose sharply in February 2026.
Why “is my FY2025 report due?” has 27 answers.
The scope test at Article 19a(1) says and; the transitional exemption at Article 3(1)(c) says or.
That single word makes the exemption wider than the test it exempts you from.
A member state may exempt. It is a national choice, and twenty-three of them have notified nothing.
What that means in practice
Whether a FY2025 or FY2026 report is still owed depends on the member state, not on the Directive. An adviser answering that without asking where you file is guessing.
The questionnaire you can decline.
A CSRD reporter may not require a smaller undertaking in its value chain to provide more than the voluntary standard asks.
The reference period is not the one you expect
Scope at Article 19a(1) is measured during the financial year; the cap at Article 19a(3) is measured in the preceding financial year.
Two adjacent provisions, two different periods, and the difference decides who has to answer whom.
Six things advisers still say that the law deleted.
Of seventeen CSRD consultancy pages read in full for this guide, none cited a numbered instrument.
Why this happens, and why it will keep happening
A service page states a legal position and cites nothing, so nothing on it tells the reader when it went stale.
Six of the seventeen state a repealed threshold as current, and three still promise an escalation to reasonable assurance that no longer exists in the law.
Adopted, in scrutiny, not in force.
The revised ESRS were adopted on 3 July 2026 as two delegated acts and are still in the scrutiny period.
They have no Official Journal number yet, so anything citing them as “(EU) 2026/…” is citing a number that does not exist.
Scrutiny governs entry into force. Article 3 governs application. They are not the same date.
The Commission contradicted its own act
Its announcement says the measures will apply once the two-month scrutiny period ends.
Article 3 says they apply to financial years beginning on or after 1 January 2027, which is the date to plan against.
FY2026 offers three options, not two.
Most summaries give a binary: the old standards or the new ones.
Article 2(1) actually offers a third, and it is the one most preparers will take.
The hybrid: the 2023 standards, plus eight named reliefs lifted out of the 2026 set.
The baseline is not what people name
Article 2(1) points at the 2023 standards as last amended by Delegated Regulation (EU) 2025/1416.
A page that says “ESRS 2023” without that amendment names a version the provision does not point at.
Immaterial disclosure is now prohibited.
ESRS 1 paragraph 24 says the undertaking shall not disclose information that is not material.
That is a prohibition, where the previous drafting merely said it was not required.
The Commission changed EFRAG’s wording on purpose, and recorded that it had.
The top-down approach is an option
Paragraph 27 allows a conclusion without further assessment where strategy and business model make it evident.
It does not replace the bottom-up assessment, which paragraph 28 preserves and the guidance allows you to combine.
Limited assurance, full stop.
The empowerment to adopt reasonable assurance standards has been removed from the law.
The date that moved, and the one that vanished
The deadline for limited assurance standards moved to 1 July 2027, so any page citing 1 October 2026 is stale.
The 2028 escalation to reasonable assurance did not move; it was deleted, and recital 5 says why.
Who may sign the assurance opinion.
The default is the statutory auditor of your financial statements.
Beyond that, a member state may allow a different audit firm, or an accredited independent assurance services provider.
“Can a non-audit firm assure my CSRD report?” is a twenty-seven-way answer.
One protection travels with the opinion
Article 34(2a) requires the opinion to be prepared in a way that fully respects a small supplier’s right to decline.
The cap therefore binds the assurer, not only the reporter.
The climate transition plan duty is gone.
Article 22 of the due-diligence directive required companies to adopt and put into effect a climate transition plan.
Omnibus I deleted it in its entirety, and removed the matching limb from the directive’s own subject matter.
Not one of the seventeen consultancy pages we read mentions this at all.
Two more deletions worth knowing
The EU-wide civil liability regime was removed, leaving liability to national law.
The phase-in was abolished as well, so a single date now applies to everyone in scope.
The regime a UK parent might eventually meet.
A non-EU parent with large EU turnover falls under a separate standard that does not yet exist.
It is called ESRS-40a, and two earlier names for it are still circulating.
Technical advice is due January 2027. No adoption date has been stated, and we will not invent one.
The dates that are settled
Third-country provisions apply for financial years starting on or after 1 January 2028, with first reports in 2029.
That is far enough out that buying readiness for it today is difficult to justify.
Four member states have notified anything.
Belgium, Croatia, Poland and Finland have notified measures; the other twenty-three show none.
That is not a scandal, because the deadline for Articles 1 to 3 is 19 March 2027.
Three transposition clocks get conflated. They are 6 July 2024, 31 December 2025 and 19 March 2027.
Why it matters to your answer
The FY2025 exemption is a national option, so it exists only where a member state has actually taken it.
Until a state legislates, the honest answer for that state is that it is not yet settled.
What a CSRD engagement actually involves.
Pick the route that reaches you and the panel returns the workstreams that follow from it, in order.
Where the money actually goes
The expensive workstreams are the double materiality assessment and the first value-chain data collection.
Both are judgement-heavy, both are auditable, and neither is a software purchase.
Five questions to ask any CSRD consultant.
Each one has a checkable answer, and each is something a page written before March 2026 gets wrong.
They take about two minutes and they are the cheapest due diligence available.
Apply them to this page as well. That is the point of publishing them.
What a wrong answer tells you
A wrong answer is rarely dishonesty; it is usually a page that has not been re-read since the Omnibus.
The useful signal is whether the adviser can name the provision when asked, not whether they were right first time.
Check scope first. Most of this will not reach you.
Then buy narrowly.
Every duty on this page, by provision.
What you told the instruments, read back.
Nothing on this page is stored, sent or remembered.
The panel simply repeats the figures you set, so you can carry them into a conversation.
What we do, stated plainly.
We are an independent editorial reference, and we also take a small amount of advisory work.
We hold no certification, no accreditation and no regulatory authorisation, and we name no clients.
What we will not do
Where an engagement needs a statutory auditor or an accredited assurance provider, that is not us, and this page says which tasks those are.
What this page will not tell you.
No CSRD compliance cost figure appears here, because our fact store holds none that survives checking.
The cost estimates in circulation come from EFRAG’s appraisal of its own draft, which the Commission’s memorandum expressly says is not the adopted act.
And two counts we will not give
No count of companies in scope appears either, before or after the Omnibus, and the widely-quoted fifty thousand is a pre-Omnibus estimate we will not restate.
We do not list which member states have opened the assurance options, because no primary source we can reach names them.
The reference, topic by topic.
What to take out of this page.
CSRD consultancy: questions readers ask.
Every claim, and where it came from.
Every figure on this page is cited inline to the instrument that carries it, named to the provision.
Each entry says what kind of document it is — a directive, a delegated act, an official register, a standard-setter’s own text, or a labelled secondary source.
Where a measure is adopted but not yet in force, or proposed rather than made, it says so.
- Directive (EU) 2026/470 — Omnibus I, Official Journal PDF
- Accounting Directive 2013/34/EU — consolidated text
- Directive (EU) 2022/2464 — the CSRD
- Directive (EU) 2025/794 — “stop the clock”
- Companies Act 2006 section 414CB
- SI 2018/1155 — SECR
- Commission Recommendation (EU) 2025/1710
- Directive 2014/95/EU — the NFRD
- Directive (EU) 2026/470 — CELEX text
- UK SRS S1 and S2 — DBT publication
- FCA CP26/5
- C(2026) 5010 final — the revised ESRS
- C(2026) 5011 final — the voluntary standard
- European Commission announcement, 3 July 2026
- C(2026) 5010 final, Annex I — the ESRS text
- Delegated Regulation (EU) 2025/1416
- Delegated Regulation (EU) 2023/2772
- EFRAG — sustainability reporting
- IFRS S1 — IFRS Foundation
- GRI Standards
- Directive (EU) 2026/470 — ELI text
- Regulation (EU) 2020/852 — the EU Taxonomy
- Directive 2006/43/EC — the Audit Directive
- ISSA (UK) 5000 — FRC
- Directive (EU) 2024/1760 — the CSDDD
- EFRAG — ESRS-40a exposure draft, basis for conclusions
- Directive (EU) 2024/1306
- EFRAG — ESRS for third-country undertakings
- EUR-Lex — national transposition measures for Directive (EU) 2026/470
- European Commission — corporate sustainability reporting
- GHG Protocol Corporate Standard
Carried over, so no citation is lost
The fact record from which every entry is drawn is the cluster’s reference at uksrs.org.uk.