Independent reference · post-Omnibus scope · updated September 2026

CSRD consultancy

Most UK companies told they were in scope no longer are. Check first.

The rules changed. Most advice did not.
Next — what the Omnibus did
Omnibus I, by what it didsix changes
Each row is one change made by Directive (EU) 2026/470. Deleted means the provision is gone from the consolidated text, not suspended.
01 · The reset

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.

So the first question is whether it reaches you.
Next — the four routes in
02 · Exposure

Does CSRD reach you at all?

The United Kingdom is outside the CSRD, so a UK company is never in scope by being British.

The four routes in, and noneset your figures
Each verdict names the provision it comes from. The test is cumulative on both limbs, and the third-country limb has a two-year persistence test.

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.

One question has twenty-seven different answers.
Next — and, or, and the gap
03 · The asymmetry

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.

And if you are the supplier, not the reporter?
Next — the right to decline
04 · The cap

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.

Must you answer it?four questions
The cap protects undertakings that do not exceed 1,000 employees in the preceding financial year. It applies only where the request is made to satisfy a CSRD obligation.

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.

Most UK companies told they were in scope no longer are. The test is now cumulative, and it is large.
Descend into what your adviser may still be telling you.
Six claims we found published against the provisions that deleted them — which standards apply and when — the assurance level that was quietly withdrawn — and the duty that no longer exists.
05 · The audit

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.

Still circulating · and the provision that killed itsix claims
Each tab pairs a claim we found published with the provision that removed it. Every one was live on a ranking page in September 2026.

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.

Start with the standards themselves.
Next — six claims, audited
06 · The standards

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.

Which leaves one awkward year in the middle.
Next — three dates, one act
07 · The middle year

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.

Materiality did not tighten. It changed kind.
Next — the year with three options
08 · Materiality

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.

Then the promise that was quietly withdrawn.
Next — a prohibition, not a relief
09 · Assurance

Limited assurance, full stop.

The empowerment to adopt reasonable assurance standards has been removed from the law.

What is assured, and to what levelthe perimeter
The perimeter includes the process used to identify the information reported, and the Taxonomy Article 8 disclosures.

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 signs it is a national question.
Next — the level, and the perimeter
Three tiers, two of them optionalmember state choice
Only the first tier is required everywhere. The other two exist only where a member state has opened them.
10 · The signature

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 transition plan duty went with it.
Next — who may sign
What Omnibus I did to the due-diligence directivefour changes
Article 22 is deleted outright, not deferred. The consolidated text runs from Article 21 to Article 23.
Read next Transition plans
11 · Due diligence

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.

One regime is still coming, slowly.
Next — the duty that was deleted
The third-country standardESRS-40a
The empowerment survives Omnibus I. The deadline attached to it has expired twice, and nothing attaches a consequence to the miss.
12 · Third country

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.

And nobody, yet, is late.
Next — the standard still being drafted
Member states that have notified a measurefour of twenty-seven
A notified measure is not a complete transposition, and a zero today is not non-compliance. The deadline is 19 March 2027.
13 · Transposition

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.

That is the regime. What remains is the work, and how to tell whether the person selling it has read the instrument.
Rise to what an engagement actually contains.
So what should an engagement actually contain?
Next — four of twenty-seven
14 · The work

What a CSRD engagement actually involves.

Pick the route that reaches you and the panel returns the workstreams that follow from it, in order.

The workstreams your route implieschoose a route
Ordered because the order matters: a materiality assessment run before the reporting boundary is fixed has to be run again.

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.

And how do you tell good advice from confident advice?
Next — the workstreams, in order
15 · The test

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.

16 · The record

Every duty on this page, by provision.

17 · Your position

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.

Your position, as set
routes reach you
— · What we offer

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.

18 · The omissions

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.

— · Carry this

What to take out of this page.

— · Questions

CSRD consultancy: questions readers ask.

Does CSRD apply to UK companies?
Not directly. The United Kingdom is outside the CSRD, so a UK company is never in scope by being British. Exposure arises only through an EU undertaking of your own that meets the scope test, securities admitted to an EU regulated market, or the third-country regime for large non-EU parents.
What is the CSRD scope threshold now?
An undertaking is in scope where it exceeds both a net turnover of EUR 450 million and an average of 1,000 employees during the financial year. The test is cumulative: both limbs, or you are out. It applies to financial years beginning on or after 1 January 2027.
Is the CSRD threshold 1,750 employees?
No. The 1,750 figure circulated between the December 2025 political agreement and the adopted text of February 2026, and it is still circulating. It appears nowhere in Directive (EU) 2026/470. The figure is 1,000 employees, and it must be met together with EUR 450 million net turnover.
Do I still have to file a CSRD report for a financial year starting in 2025?
That depends on which member state you file in, and there is no single answer. Article 3(1)(c) of Directive (EU) 2026/470 lets a member state exempt undertakings that do not exceed EUR 450 million net turnover or 1,000 employees for financial years starting between 1 January 2025 and 31 December 2026. Note the or: the exemption is wider than the scope test, and taking it is a national choice.
Can I refuse to complete a customer's CSRD questionnaire?
If your undertaking does not exceed an average of 1,000 employees in the preceding financial year, a CSRD reporter may not require you to provide more than the content of the voluntary standard for smaller undertakings. That is the value-chain cap at Article 19a(3). It applies where the request is made to satisfy a CSRD obligation; it does not stop a customer asking, and it does not stop you answering if you want to.
Do I need a CSRD consultant?
Check the scope test first, because most UK companies that were told they were in scope no longer are. If no route reaches you, the honest answer is that you do not need a CSRD readiness programme. If one does, the judgement-heavy work is the double materiality assessment and the first value-chain data collection, and those are what advice is genuinely worth buying.
What does a CSRD consultant actually do?
In order: confirm which route brings you into scope and fix the reporting boundary, run the double materiality assessment, map the datapoints that survive it, build the value-chain data collection, draft the sustainability statement, and prepare for a limited assurance engagement. Running the materiality assessment before the boundary is fixed means running it twice.
How much does CSRD consultancy cost?
We do not publish a figure, because our fact record holds no cost figure that survives checking. The estimates in circulation come from EFRAG's appraisal of its own draft standards, which the Commission's explanatory memorandum expressly says is not the adopted act. Treat any quoted market rate as that publisher's claim rather than an established benchmark.
What level of assurance does CSRD require?
Limited assurance, and only limited assurance. The empowerment to adopt reasonable assurance standards was removed by Directive (EU) 2026/470; recital 5 says the requirement should be removed to avoid increasing assurance costs. Any adviser telling you the regime escalates to reasonable assurance in 2028 is describing a deleted empowerment.
Who can sign a CSRD assurance opinion?
By default the statutory auditor of your financial statements. Beyond that, a member state may allow a different statutory auditor or audit firm, and may allow an accredited independent assurance services provider. Both are options rather than requirements, so the answer differs by member state.
When do the revised ESRS apply?
The revised standards apply to financial years beginning on or after 1 January 2027, under Article 3 of the delegated act. They were adopted on 3 July 2026 and remain in the scrutiny period, so they are adopted but not yet in force, and they carry no Official Journal number yet. The Commission's own announcement says they apply once scrutiny ends, which contradicts Article 3.
Which ESRS apply for a financial year starting in 2026?
There are three options, not two. The 2023 standards as last amended by Delegated Regulation (EU) 2025/1416; the 2026 standards in full; or a hybrid of the 2023 standards plus eight named reliefs taken from the 2026 set. Whichever is chosen, the undertaking must state in its sustainability statement which version it applied.
Is immaterial ESRS disclosure still allowed?
No. ESRS 1 paragraph 24 in the 2026 standards says the undertaking shall not disclose information prescribed by a disclosure requirement or datapoint if that information is not material. The explanatory memorandum records this as a deliberate change from the drafting that said the undertaking was merely not required to report it.
Are sector-specific ESRS still coming?
No. The empowerment to adopt sector-specific standards was deleted by Article 2(6)(a) of Directive (EU) 2026/470, and the listed-SME standard at Article 29c was deleted by Article 2(7). What remains is a recital-level possibility that the Commission could offer non-binding sector guidance.
Does CSRD still require a climate transition plan?
The transition plan duty in the due-diligence directive is gone. Article 22 of Directive (EU) 2024/1760 was deleted in its entirety by Article 4(16) of Directive (EU) 2026/470, and the matching limb was removed from the directive's own subject matter. Recital 47 gives the reason.
When does the third-country CSRD regime start?
Third-country provisions apply for financial years starting on or after 1 January 2028, with first reports in 2029. The standard itself does not exist yet: it is ESRS-40a, EFRAG consulted on an exposure draft to 31 October 2026, and technical advice is due in January 2027. No Commission adoption date has been stated.
Has the NFRD been repealed?
No, and that is the confusion. EUR-Lex still shows Directive 2014/95/EU as in force. It was an amending directive, and the Articles it inserted into the Accounting Directive were overwritten first by the CSRD and again by the Omnibus. The instrument is spent rather than repealed, which is why a repeal search returns nothing.
How many member states have transposed Omnibus I?
Four have notified any measure: Belgium, Croatia, Poland and Finland. The other twenty-three show none. Nobody is late, because the deadline for Articles 1 to 3 is 19 March 2027, and Article 4 runs to 26 July 2028. A notified measure is also not the same as a complete transposition.
What is the difference between CSRD and ESRS?
The CSRD is the directive that creates the obligation to report. The ESRS are the standards that say what the report must contain, adopted as delegated acts under the Accounting Directive. You are in scope of the directive; you report under the standards.
Should we buy CSRD software or CSRD advice first?
Neither, until the scope test is answered. If a route does reach you, the sequence matters more than the purchase: fix the boundary, then run materiality, and only then choose a system, because the datapoints that survive the materiality assessment determine what the system has to collect.
— · The record

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.

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.

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