CSRD consultancy · for UK groups
CSRD consultancy
CSRD consultancy is advice on the EU’s Corporate Sustainability Reporting Directive, and since Directive (EU) 2026/470 most UK groups that were told they needed it no longer do.
An undertaking is now in scope only if it exceeds both €450 million net turnover and an average of 1,000 employees, for financial years beginning on or after 1 January 2027.
This page reads the scope test, the value-chain cap, the revised ESRS and the assurance rules at the provision, then sets out what an engagement contains if one is needed.
The reset
What Omnibus I actually changed
Module 01 / 04
Scope: €450m turnover and 1,000 employees, b
Module 02 / 04
FY2025–26 member-state exemption, with “or”
Module 03 / 04
Value-chain cap at 1,000 employees
Module 04 / 04
Reasonable assurance empowerment removed
| Change | Provision |
|---|---|
| Scope: €450m turnover and 1,000 employees, both | Art 19a(1) as amended |
| FY2025–26 member-state exemption, with “or” | Dir 2026/470 Art 3(1)(c) |
| Value-chain cap at 1,000 employees | Art 19a(3) |
| Reasonable assurance empowerment removed | Dir 2026/470 recital 5, Art 1(3) |
| Sector standards and listed-SME standard deleted | Dir 2026/470 Art 2(6)(a), 2(7) |
| CSDDD transition plan duty deleted | Dir 2026/470 Art 4(16) |
Read the detailed guidance and evidence
Directive (EU) 2026/470 was published on 26 February 2026 and entered into force on 18 March 2026.
It did not soften the regime at the edges; it removed most of the population from it.
The Commission’s own staff working document says the new thresholds reduce the number of companies in scope by about 85%, and estimates the remaining population at about 6,753 companies (SWD(2026) 500).
That figure is the population that remains after Omnibus I, not an EU-wide count of every company that reports.
The scope test in the consolidated Accounting Directive is now a single cumulative test: exceed both limbs, or you are out.
It amends the CSRD of 2022 and follows the “stop the clock” directive of 2025, which had deferred the dates before the scope itself was reset.
The plain-English background is on CSRD and the UK, and the standards themselves on European sustainability reporting standards.
Exposure
Does the CSRD reach a UK company at all?
Module 01 / 04
An EU undertaking of your own
Module 02 / 04
A supplier to an EU reporter
Module 03 / 04
The third-country regime
Module 04 / 04
Key point 01
Which CSRD route reaches you
Indicative, not advice.
Euro amounts are the directive’s; a sterling group converts at its own documented rate.
Nothing you enter leaves your browser.
Read the detailed guidance and evidence
The United Kingdom is outside the CSRD, so a UK company is never in scope for being British.
Exposure arises through an EU undertaking of your own, through the third-country regime, or indirectly as a supplier, and each threshold rose sharply in February 2026.
An EU undertaking of your own
An EU subsidiary is in scope only if it exceeds €450 million net turnover and 1,000 employees on average during the financial year (Art 19a(1)), and an EU parent on a consolidated basis under Article 29a(1).
A supplier to an EU reporter
A UK company with no EU entity of its own may still be asked for data by an EU customer in scope, which is where the value-chain cap below protects it.
The third-country regime
A non-EU group is caught under Article 40a if it has EU net turnover above €450 million in each of the last two financial years and an EU subsidiary or branch above €200 million, for financial years from 1 January 2028.
The panel applies those tests and names the provision behind each answer; for a UK group with overseas operations, overseas companies and UK SRS covers the UK side.
What reaches a large UK company at home is different: SECR under SI 2018/1155, ESOS, and for the largest the climate disclosures in section 414CB of the Companies Act.
Those are set out on the UK ESG reporting requirements, with the SECR test on SECR thresholds and the UK SRS scope on UK SRS thresholds.
And, or
Why “is my FY2025 report due?” has twenty-seven answers
Module 01 / 04
Scope, Art 19a(1)
Module 02 / 04
Exemption, Dir 2026/470 Art 3(1)(c)
Module 03 / 04
Reliefs
Module 04 / 04
Reliefs · 2
| Test | Conjunction | Effect |
|---|---|---|
| Scope, Art 19a(1) | and | In scope only if both limbs are exceeded |
| Exemption, Dir 2026/470 Art 3(1)(c) | or | A member state may exempt anyone not exceeding either limb, FY2025–FY2026 |
Read the detailed guidance and evidence
The scope test says “and”; the transitional exemption says “or”.
Article 3(1)(c) of Directive (EU) 2026/470 lets a member state exempt undertakings that do not exceed €450 million net turnover or an average of 1,000 employees, for financial years starting between 1 January 2025 and 31 December 2026.
That one word makes the exemption wider than the test, and because it is a member-state option, whether a FY2025 or FY2026 report is still owed depends on where you file.
At the Bible’s re-read of 11 September 2026, the EUR-Lex transposition page listed notified measures from four member states — Belgium, Croatia, Poland and Finland — and none from the other twenty-three.
Nobody is late: the deadline for Articles 1 to 3 is 19 March 2027, and Article 4, the due-diligence limb, runs to 26 July 2028.
A notified measure is also not necessarily a complete transposition, so until a state legislates, the honest answer for that state is that it is not yet settled.
An adviser who answers the FY2025 question without asking where you file is guessing.
The value-chain cap
The questionnaire a supplier may decline
Module 01 / 04
Provision
Module 02 / 04
Measured
Module 03 / 04
Line
Module 04 / 04
From
| Scope | Cap | |
|---|---|---|
| Provision | Art 19a(1) | Art 19a(3) |
| Measured | During the financial year | In the preceding financial year |
| Line | Over 1,000 and over €450m | 1,000 employees or fewer |
| From | FY2027 | FY2027 |
Read the detailed guidance and evidence
Most UK companies meet the CSRD as suppliers, through a customer’s questionnaire.
A CSRD reporter may not require an undertaking in its value chain that averaged 1,000 employees or fewer in the preceding financial year to provide more than the voluntary standard covers (Art 19a(3)).
The voluntary standard is Delegated Regulation (EU) 2026/1560, in force since 24 September 2026 and applying from FY2027; it replaced the 2025 VSME recommendation as the basis.
The cap 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.
It binds the assurer too: the assurance opinion must be prepared in a way that respects a protected supplier’s right to decline (Art 34(2a)).
For a smaller company the practical answer is a clean Scope 1 and 2 figure and a short statement against the voluntary standard; SME sustainability reporting and Scope 3 emissions cover the rest.
For UK suppliers
Answering an EU customer’s request without a CSRD programme
For most UK companies the CSRD arrives as a spreadsheet from a customer.
The useful response is narrow, and it starts with three facts about yourself.
Module 01 / 04
1
Module 02 / 04
2
Module 03 / 04
3
Module 04 / 04
4
Read the detailed guidance and evidence
| Step | What to do | Why |
|---|---|---|
| 1 | Check your average headcount for the preceding financial year | At 1,000 or fewer you are protected by the cap in Art 19a(3) |
| 2 | Ask whether the request is made to meet the customer’s CSRD obligation | The cap applies to requests made for that purpose |
| 3 | Answer from the voluntary standard, DR (EU) 2026/1560 | The ceiling a CSRD reporter may require from a protected supplier |
| 4 | Give Scope 1 and 2 figures with the method and factor year | The figure most customers actually need for their Scope 3 |
| 5 | Say plainly what you are not providing, and why | The cap is a right to decline, not a duty to refuse |
Nothing stops a supplier answering more than the cap requires, and a commercial relationship may make it sensible to do so.
What the cap changes is the default: a protected supplier no longer needs a CSRD readiness project to keep a customer, and a measured Scope 1 and 2 figure built to the GHG Protocol usually covers the core of the request.
The UK reporting a supplier may already do — SECR in the directors’ report under SI 2018/1155 — produces exactly that figure.
The record
The CSRD dates that matter to a UK group
Module 01 / 04
Key point 01
Module 02 / 04
Boundary
Module 03 / 04
Assurance
Module 04 / 04
Disclosure
- 26 Feb 202601
Directive (EU) 2026/470 published
- 18 Mar 202602
Omnibus I in force
- 21 Sep 202603
Revised ESRS and voluntary standard published
- 1 Jan 202704
Revised ESRS and the value-chain cap apply
Financial years beginning on or after.
- 19 Mar 202705
Transposition deadline, Articles 1–3
- 1 Jul 202706
Limited assurance standards due from the Commission
- 1 Jan 202807
Third-country regime applies
First reports in 2029.
- 26 Jul 202808
Transposition deadline, Article 4 (CSDDD)
Read the detailed guidance and evidence
Three kinds of date are routinely run together: when an act was published, when it entered into force, and when it applies.
For a UK group the dates that change the work are the application dates: FY2027 for an EU subsidiary in scope and for the value-chain cap, and FY2028 for the third-country regime.
The transposition deadlines matter only where a member state’s choice changes the answer, as with the FY2025–26 exemption and the assurance options.
Every date in the timeline is read from the instrument that sets it, linked in the sources below, and the wider UK picture is on sustainability reporting.
The audit
Things still said about the CSRD that the law deleted
Module 01 / 04
The threshold that never was
Module 02 / 04
The standards that will not come
Module 03 / 04
The directive that was not repealed
Module 04 / 04
The limited-reporting route
Claim check · still true after Omnibus I?
- A company with more than 250 employees is in CSRD scope.
- The employee threshold is 1,750.
- CSRD assurance escalates to reasonable assurance in 2028.
- Sector-specific ESRS are still coming.
- The EU due-diligence directive requires a climate transition plan.
- Under the 2026 ESRS a company may disclose immaterial information if it wishes.
- The revised ESRS apply to financial years beginning on or after 1 January 2027.
- A supplier with 1,000 or fewer employees can decline a CSRD data request beyond the voluntary standard.
Answer any claim to see the provision behind it.
Use it on any adviser, including this page.
Nothing you select leaves your browser.
Read the detailed guidance and evidence
A service page states a legal position and cites nothing, so nothing on it tells the reader when it went stale.
The claims in the panel were all in circulation in September 2026, and each is paired with the provision that settles it.
The threshold that never was
The 1,750-employee figure circulated between the political agreement of December 2025 and the adopted text, and it appears nowhere in Directive (EU) 2026/470.
The standards that will not come
The empowerment to adopt sector-specific ESRS was deleted, and so was the listed-SME standard in Article 29c (Dir 2026/470 Art 2(6)(a), 2(7)).
The directive that was not repealed
The NFRD, Directive 2014/95/EU, still shows as in force on EUR-Lex: it was an amending directive whose inserted Articles were overwritten twice, so it is spent rather than repealed.
The limited-reporting route
Article 19a(6) and (7) were deleted, so no limited-reporting route survives in the consolidated text.
Use the questions on any adviser, including this page; the useful signal is whether the adviser can name the provision when asked.
The standards
The revised ESRS: published, in force and applying are three dates
Module 01 / 04
The middle year has three options
Module 02 / 04
Top-down double materiality
Module 03 / 04
Undue cost and effort; value-chain limitatio
Module 04 / 04
Acquisitions and disposals
- 3 Jul 202601
Revised ESRS adopted as C(2026) 5010
And the voluntary standard as C(2026) 5011.
- 21 Sep 202602
Both published in the Official Journal
DR (EU) 2026/1563 and 2026/1560.
- 24 Sep 202603
Voluntary standard in force
- 10 Nov 202604
Revised ESRS in force
- 1 Jan 202705
Revised ESRS apply
Financial years beginning on or after this date.
Read the detailed guidance and evidence
The revised ESRS were adopted on 3 July 2026 as C(2026) 5010 and published on 21 September 2026 as Delegated Regulation (EU) 2026/1563.
The regulation enters into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027.
The Commission’s July announcement said the measures would apply once scrutiny ended; Article 3 of the act says FY2027, which is the date to plan against.
The middle year has three options
For financial years starting in 2026, Article 2(1) offers three choices, not two.
- The 2023 standards, Delegated Regulation (EU) 2023/2772, as last amended by Delegated Regulation (EU) 2025/1416.
- The 2026 standards in full.
- A hybrid: the 2023 standards plus eight named reliefs from the 2026 set.
Whichever is chosen, the sustainability statement must say which version was applied (Art 2(2)).
| Relief in the hybrid | ESRS 1 (2026) |
|---|---|
| Top-down double materiality | ¶27 |
| Undue cost and effort; value-chain limitation | ¶¶32–33 |
| Acquisitions and disposals | ¶¶74–75 |
| Metrics for non-significant activities | ¶90 |
| Partial value-chain scope | ¶91 |
| Joint operations | ¶92 |
| Taxonomy disclosures in a separate appendix | ¶106 |
| Executive summary | ¶110 |
The Commission says the revision cuts the number of mandatory datapoints by over 60% and the total by more than 70% (Commission, 3 July 2026); those percentages are the Commission’s, not counts this page has made.
A page that says “ESRS 2023” without the 2025 amendment names a version the provision does not point at; the full reading is on the ESRS reference and on this site’s ESRS page.
The voluntary standard went through the same steps as C(2026) 5011; EFRAG holds the drafting history.
Materiality
Double materiality, and why immaterial disclosure is now prohibited
Module 01 / 04
A prohibition, not a relief
Module 02 / 04
Top-down is an option
Module 03 / 04
Materiality
Module 04 / 04
Test
| ESRS (CSRD) | UK SRS / IFRS S1 | |
|---|---|---|
| Materiality | Double: impact and financial | Single, financial |
| Test | ESRS 1 | Could influence primary users (UK SRS S1 ¶18) |
| Immaterial information | Shall not be disclosed (ESRS 1 ¶24) | Need not be disclosed |
| Who applies it | Undertakings in CSRD scope | UK listed companies under FCA rules; others voluntarily |
Read the detailed guidance and evidence
The CSRD’s defining requirement is double materiality: a matter is material if it matters to the company’s finances, or if the company has a material impact on people or the environment.
The ISSB’s standards, and UK SRS built on them, use single, financial materiality; the GRI Standards use impact materiality, and no UK instrument requires them.
A prohibition, not a relief
ESRS 1 paragraph 24 in the 2026 standards says the undertaking shall not disclose information that is not material (Annex I).
The earlier drafting said only that it was not required, and the Commission changed the wording on purpose.
Top-down is an option
Paragraph 27 allows a conclusion without further assessment where the strategy and business model make it evident; paragraph 28 keeps the bottom-up assessment, and the two may be combined.
The method is set out on double materiality and the assessment itself on double materiality assessment; the UK basis is on UK SRS S1 materiality.
A UK group reporting on both sides will find the differences on UK SRS vs CSRD, with the UK standards summarised in the UK SRS hub and IFRS on IFRS S1 and IFRS S2.
Assurance
Limited assurance, and who may sign it
Module 01 / 04
Default
Module 02 / 04
Option
Module 03 / 04
Option · 2
Module 04 / 04
Assurance
| Tier | Who | Status |
|---|---|---|
| Default | The statutory auditor of the financial statements | Everywhere (Art 34(1)) |
| Option | A different statutory auditor or audit firm | Where a member state allows (Art 34(3)) |
| Option | An accredited independent assurance services provider | Where a member state allows (Art 34(4)) |
Read the detailed guidance and evidence
The empowerment to adopt reasonable assurance standards has been removed from the law.
Recital 5 of Directive (EU) 2026/470 says the requirement should be removed to avoid increasing assurance costs, and the Commission must adopt limited assurance standards by 1 July 2027 under Article 26a(3) of the Audit Directive as replaced.
A page promising an escalation to reasonable assurance in 2028 is describing a deleted empowerment.
The opinion covers the process used to identify the information reported and the Taxonomy Article 8 disclosures, as well as the statement itself (Art 34(1)(aa)).
“Can a non-audit firm assure my CSRD report?” therefore has an answer per member state.
The UK position is a contrast: under the FCA’s final rules assurance is not required, and ISSA (UK) 5000 is for voluntary use for periods from 15 December 2026; see UK SRS assurance and ISSA (UK) 5000.
Due diligence
The climate transition plan duty is gone
Module 01 / 04
Key point 01
Module 02 / 04
Key point 02
Module 03 / 04
Legal route
Module 04 / 04
Listed categories
“Article 22 is deleted” — Directive (EU) 2026/470, Article 4(16).
The consolidated CSDDD runs from Article 21 to Article 23.
Read the detailed guidance and evidence
Article 22 of the due-diligence directive, Directive (EU) 2024/1760, required in-scope 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 subject matter.
The EU-wide civil liability regime was removed as well, leaving liability to national law.
A UK listed company meets a different, narrower question under the FCA’s PS26/19: whether it has published a transition plan and where to find it; transition plans under UK SRS covers it.
Third country
ESRS-40a: the standard a UK parent might eventually meet
Module 01 / 04
Standard
Module 02 / 04
Key point 02
Module 03 / 04
Key point 03
Module 04 / 04
Disclosure
Read the detailed guidance and evidence
A non-EU parent with large EU turnover falls under a separate standard that does not yet exist.
It is called ESRS-40a; EFRAG consulted on an exposure draft and says it will deliver technical advice by January 2027 (Basis for Conclusions, BC1).
Earlier labels such as ESRS-TC and N-ESRS are still circulating; the EFRAG project page uses the current name.
The third-country provisions apply for financial years starting on or after 1 January 2028, with first reports in 2029.
The Commission’s deadline for the delegated act, in Article 40b, has expired twice — the second time on 30 June 2026 under Directive (EU) 2024/1306 — and nothing attaches a consequence to the miss.
No adoption date has been stated, and this page will not invent one; buying readiness for a standard that does not exist is hard to justify.
Both sides
CSRD and the FCA’s UK SRS rules, side by side
A UK listed group with a large EU subsidiary may face both regimes.
They differ in almost every dimension that changes the work.
Module 01 / 04
Instrument
Module 02 / 04
Who
Module 03 / 04
Basis
Module 04 / 04
Standards
Read the detailed guidance and evidence
| CSRD (EU) | FCA rules on UK SRS (UK) | |
|---|---|---|
| Instrument | Directive 2013/34/EU as amended by Directive (EU) 2026/470 | UK Listing Rules, FCA PS26/19 |
| Who | Undertakings exceeding €450m turnover and 1,000 employees; large non-EU groups from FY2028 | Listed companies in UKLR 6, 14, 15, 16 and 22 |
| Basis | Mandatory reporting | Comply or explain |
| Standards | ESRS (2026), DR (EU) 2026/1563 | UK SRS S1 and S2 (DBT, 25 February 2026) |
| Materiality | Double | Single, financial |
| From | Financial years beginning on or after 1 January 2027 | Accounting periods beginning on or after 1 January 2027 |
| Early-year reliefs | The FY2026 hybrid; member-state FY2025–26 option | One year’s Scope 3 relief; two years for non-climate S1 matters |
| Assurance | Limited, required | Not required; if obtained, name provider, scope and standard |
| Transition plan | CSDDD Article 22 deleted | State whether one is published and where |
The shared ground is the climate data: both build emissions on the GHG Protocol, and a single inventory can serve both statements.
The divergence is materiality, and it is not cosmetic: an ESRS statement must leave out what is immaterial on a double test, while a UK SRS disclosure is judged on a financial one.
The UK rules are on the UK SRS hub, with the FCA’s final rules applying them to listed companies; the comparison in more depth is on UK SRS vs CSRD.
The Commission’s numbers
What the Commission estimated, and what it did not
Module 01 / 04
About 85%
Module 02 / 04
About 6,753
Module 03 / 04
About €4.4bn
Module 04 / 04
€2.24bn a year from 2029
| Figure | What it measures |
|---|---|
| About 85% | Reduction in companies in scope from Omnibus I |
| About 6,753 | Companies remaining in scope after Omnibus I |
| About €4.4bn | Savings from the scope reduction |
| €2.24bn a year from 2029 | Savings from the revised ESRS for those still in scope |
Read the detailed guidance and evidence
The only official numbers on the post-Omnibus regime are in the Commission’s staff working document, SWD(2026) 500.
It estimates the remaining population at about 6,753 companies, split between those that have already reported under the 2023 standards and those that will report for the first time under the revised set.
It puts the saving from the scope reduction at about €4.4 billion, and the saving from the simpler standards at €2.24 billion a year from 2029 for the companies still in scope.
The two figures measure different causes and different populations, and adding them double-counts nothing useful.
None of these figures is a consultancy fee, and none tells a UK group what its own engagement should cost.
The work
What a CSRD consultant does, in the order it has to happen
If a route does reach you, the sequence matters more than the purchase.
A materiality assessment run before the reporting boundary is fixed has to be run again.
Module 01 / 04
1
Module 02 / 04
2
Module 03 / 04
3
Module 04 / 04
4
Read the detailed guidance and evidence
| Order | Workstream | Rests on | Typical effort |
|---|---|---|---|
| 1 | Confirm the route into scope and fix the reporting boundary | Arts 19a, 29a, 40a | Short, legal |
| 2 | Double materiality assessment | ESRS 1 ¶¶27–28 | Judgement-heavy |
| 3 | Map the datapoints that survive materiality | ESRS 2 and topical standards | Mechanical once 2 is done |
| 4 | Value-chain data collection, within the cap | Art 19a(3); DR (EU) 2026/1560 | The slowest, first time |
| 5 | Draft the sustainability statement, stating the ESRS version | DR (EU) 2026/1563 Art 2(2) | Iterative |
| 6 | Prepare for limited assurance | Art 34; Audit Directive Art 26a | Built from step 1, not at the end |
The expensive workstreams are the double materiality assessment and the first value-chain data collection: both are judgement-heavy, both are assured, and neither is a software purchase.
Emissions data under the climate standard is built to the GHG Protocol, so a UK group with a SECR inventory already has the start of it; see the GHG Protocol page.
Choose a system after materiality, not before, because the datapoints that survive decide what it has to collect; the platforms are on CSRD reporting software.
Financial groups have a further layer, set out on UK SRS for financial services.
Due diligence
Five questions to ask any CSRD consultant
Module 01 / 04
Key point 01
Module 02 / 04
Key point 02
Module 03 / 04
Disclosure
Module 04 / 04
Key point 01 · 2
What a right answer cites
- Question 1: Art 19a(1) and 40a(1).
- Question 2: Dir 2026/470 Art 3(1)(c) and the member state.
- Question 3: Dir 2026/470 recital 5; Art 34(3)–(4).
- Question 4: DR (EU) 2026/1563 Arts 2–3.
- Question 5: Dir 2026/470 Art 4(16).
Read the detailed guidance and evidence
- Which route brings us into scope, and on which figures? A firm that cannot name Article 19a(1) or 40a(1) has not checked.
- Is a FY2025 or FY2026 report still owed where we file? The answer depends on the member state’s choice under Article 3(1)(c).
- What level of assurance, and who may sign? Limited only; the signatory depends on member-state options.
- Which ESRS version will we report under, and from when? Three options for FY2026, the 2026 set from FY2027.
- Do we need a CSDDD transition plan? Article 22 is deleted.
Each has a checkable answer, and each is something a page written before March 2026 gets wrong.
A wrong answer is rarely dishonesty; it is usually a page nobody re-read after the Omnibus.
The adjacent specialisms are on sustainability reporting consultants, carbon consultancy and net zero consultancy, and the wider subject on sustainability reporting.
Where this site fits
What this page does not give, and a free 15-minute call
Module 01 / 04
Legal route
Module 02 / 04
Standard
Module 03 / 04
Assurance
Module 04 / 04
Disclosure
Read the detailed guidance and evidence
No CSRD consultancy fee figure appears here, because no regulator publishes one.
The cost estimates in circulation come from EFRAG’s appraisal of its own draft standards, which the Commission’s memorandum says is not the adopted act.
No list of the member states that have opened the assurance options appears either, because no primary source in reach names them.
The Commission’s corporate sustainability reporting page is the place to watch for both.
The UK side of the comparison is UK SRS S1 and S2, which the FCA’s final rules apply to listed companies on a comply-or-explain basis; the consultation those rules finalised was CP26/5.
This site is an independent reference: it holds no certification, accreditation or regulatory authorisation, and signs no assurance opinion.
Readers who want to talk a situation through can book a free 15-minute call or send the question in writing.
More reference reading sits on uksrs.org.uk, including the ESOS Phase 4 compliance guide; this site’s terms and privacy notice apply.
Frequently asked
CSRD consultancy: questions people ask
Does CSRD apply to UK companies?
Not directly.
The United Kingdom is outside the CSRD, so a UK company is never in scope for being British.
A UK group meets it through an EU undertaking of its own that passes the scope test, or through the third-country regime for large non-EU groups, which applies from financial years starting on or after 1 January 2028.
A UK supplier may also receive data requests from EU customers in scope.
What is the CSRD scope threshold now?
An undertaking is in scope if it exceeds both a net turnover of €450 million and an average of 1,000 employees during the financial year, under Article 19a(1) of the Accounting Directive as amended by Directive (EU) 2026/470.
The test is cumulative and applies to financial years beginning on or after 1 January 2027.
Is the CSRD threshold 1,750 employees?
No. The 1,750 figure circulated before the Omnibus directive was adopted and appears nowhere in Directive (EU) 2026/470.
The figure is 1,000 employees, together with €450 million net turnover.
Do I need a CSRD consultant?
Check the scope test first, because most UK groups told in 2024 and 2025 that they were in scope no longer are.
If no route reaches you, 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.
What does a CSRD consultant do?
In order: confirm the route 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 materiality before the boundary is fixed means running it twice.
Can I refuse a customer’s CSRD questionnaire?
If your undertaking averaged 1,000 employees or fewer in the preceding financial year, a CSRD reporter may not require more from you than the voluntary standard covers, where the request is made to meet its CSRD obligation.
The cap is in Article 19a(3) and applies from financial years beginning on or after 1 January 2027.
When do the revised ESRS apply?
To financial years beginning on or after 1 January 2027.
Delegated Regulation (EU) 2026/1563 was published on 21 September 2026 and enters into force on 10 November 2026.
For financial years starting in 2026 there are three options: the 2023 standards as amended in 2025, the 2026 standards in full, or a hybrid with eight named reliefs, and the statement must say which.
What level of assurance does CSRD require?
Limited assurance only.
Directive (EU) 2026/470 removed the empowerment to adopt reasonable assurance standards, and the Commission must adopt limited assurance standards by 1 July 2027.
By default the statutory auditor signs; a member state may allow another audit firm or an accredited independent assurance services provider.
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 Directive (EU) 2026/470.
For a UK listed company, the FCA’s rules ask instead whether it has published a transition plan and where to find it.
Is CSRD the same as UK SRS?
No. The CSRD is EU law applying the ESRS, with double materiality and limited assurance.
UK SRS S1 and S2 are UK standards built on IFRS S1 and S2, with single, financial materiality; the FCA applies them to listed companies on a comply-or-explain basis for periods from 1 January 2027, and they are voluntary for everyone else.
How much does CSRD consultancy cost?
No regulator publishes a fee figure.
The Commission’s staff working document estimates savings and costs for companies in scope, not consultancy fees.
The variables that move a quote are the number of EU entities in the boundary, whether a double materiality assessment already exists, the state of value-chain data and the member state’s assurance rules.
What is the difference between CSRD and ESRS?
The CSRD is the directive that creates the obligation to report, now in the Accounting Directive as amended.
The ESRS are the standards that say what the report contains, adopted as delegated regulations.
A company is in scope of the directive and reports under the standards.
Which ESRS apply for a financial year starting in 2026?
There are three options: the 2023 standards as last amended by Delegated Regulation (EU) 2025/1416, the 2026 standards in full, or a hybrid of the 2023 standards with eight named reliefs from the 2026 set.
The sustainability statement must say which version was applied.
Is immaterial ESRS disclosure still allowed?
No. ESRS 1 paragraph 24 in the 2026 standards says the undertaking shall not disclose information that is not material.
The earlier drafting said only that it was not required.
Are sector-specific ESRS still coming?
No. Directive (EU) 2026/470 deleted the empowerment to adopt sector-specific standards and the listed-SME standard.
Has the NFRD been repealed?
No. Directive 2014/95/EU still shows as in force on EUR-Lex.
It was an amending directive whose inserted Articles were overwritten by the CSRD and again by Omnibus I, so it is spent rather than repealed.
Should we buy CSRD software or CSRD advice first?
Neither, until the scope test is answered.
If a route reaches you, fix the boundary, run the materiality assessment, and only then choose a system, because the datapoints that survive materiality decide what the system has to collect.
How many member states have transposed Omnibus I?
At 11 September 2026, EUR-Lex listed notified measures from four member states — Belgium, Croatia, Poland and Finland — and none from the other twenty-three.
Nobody is late: the deadline for Articles 1 to 3 is 19 March 2027, and a notified measure is not necessarily a complete transposition.
Prepare the evidence
CSRD consultancy: from a requirement to a reporting pack
Use this preparation sequence alongside the detailed requirements on this page.
An editorial workflow, not a statutory schedule.
- Stage 0101
Written brief
Specify the organisation, reporting route and decisions the advice must support.
- Stage 0202
Defined deliverables
Name the inventory, assessment, disclosure or evidence pack expected.
- Stage 0303
Source-led method
Ask how the adviser uses current primary instruments and records assumptions.
- Stage 0404
Responsibilities
Separate advice from management ownership, approval and any independent assurance.
- Stage 0505
Acceptance check
Agree how each deliverable will be reviewed and accepted.
- Stage 0606
Handover
Retain editable working files, source references and the outstanding decisions.
Read the applicable instrument: Directive (EU) 2026/470 (Omnibus I) — Arts 1–6; in force 18 March 2026
A practical brief
An evidence pack, with a clear review trail
Ask for a pack that lets the next reviewer retrace the scope decision, follow the evidence and understand the limitations.
This describes a useful handover; it does not certify compliance or establish that a vendor or adviser delivers it.
Module 01 / 04
Applicability record
Write down the entity, reporting route and relevant period, including why the route applies.
Module 02 / 04
Evidence register
Attach each reported figure or statement to its source, method, version and limitations.
Module 03 / 04
Review trail
Name the preparer, reviewer, open questions and decisions taken before publication.
Module 04 / 04
Usable handover
Retain the working files and unresolved actions so the next reporting cycle can reuse the evidence.
View the preparation diagram
- Prepare01
Create the traceable pack
Keep the input records, calculation files and narrative together.
- Challenge02
Resolve questions before publication
Record the assumptions challenged and any limitations still unresolved.
- Retain03
Make the next cycle reproducible
Keep the approved version and the actions carried forward.
Continue your research
Related guides, one question at a time
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- EUR-LexDirective (EU) 2026/470 (Omnibus I) — Arts 1–6; in force 18 March 2026
The reset: scope, assurance, deletions, transposition dates.
- EUR-LexDirective (EU) 2026/470 — Official Journal PDF
Art 3(1)(c), the FY2025–2026 member-state option, read in full.
- EUR-LexDirective (EU) 2026/470 — CELEX text
- EUR-LexDirective 2013/34/EU, consolidated to 18 March 2026 — Arts 19a, 29a, 34, 40a, 40b
The scope test, the value-chain cap, assurance and the third-country regime.
- EUR-LexNational transposition measures for Directive (EU) 2026/470
Four member states with notified measures at 11 September 2026.
- EUR-LexDirective (EU) 2022/2464 — the CSRD
- EUR-LexDirective (EU) 2025/794 — “stop the clock”
- EUR-LexDirective (EU) 2024/1306 — Article 40b deadline moved
- EUR-LexDelegated Regulation (EU) 2026/1563 — the revised ESRS
Published 21 September 2026; in force 10 November 2026; applies from FY2027.
- EUR-LexDelegated Regulation (EU) 2026/1560 — the voluntary standard
In force 24 September 2026; the value-chain cap.
- Council of the EUC(2026) 5010 final — revised ESRS as transmitted, Arts 2–3
The FY2026 options and the application date.
- Council of the EUC(2026) 5010 final, Annex I — ESRS 1 ¶¶24, 27–28
“Shall not disclose” immaterial information.
- Council of the EUC(2026) 5011 final — the voluntary standard as transmitted
- EUR-LexDelegated Regulation (EU) 2023/2772 — ESRS as first adopted
- EUR-LexDelegated Regulation (EU) 2025/1416 — the 2025 amendment
- EUR-LexRecommendation (EU) 2025/1710 — VSME
- EUR-LexDirective (EU) 2024/1760 — CSDDD
Article 22 deleted by Omnibus I.
- EUR-LexDirective 2006/43/EC — Art 26a(3) as replaced
Limited assurance standards by 1 July 2027.
- EUR-LexRegulation (EU) 2020/852 — Taxonomy, Art 8
- EUR-LexDirective 2014/95/EU — NFRD
Spent rather than repealed.
- European CommissionSWD(2026) 500 final
About 6,753 companies remain in scope after Omnibus I.
- European CommissionCorporate sustainability reporting
- European CommissionCommission adopts revised sustainability reporting standards, 3 July 2026
- EFRAGESRS-40a exposure draft — Basis for Conclusions, BC1, BC44
Technical advice by January 2027; FY2028 application.
- EFRAGESRS for third-country undertakings — project page
- EFRAGSustainability reporting
- IFRS FoundationIFRS S1 — general requirements
Single, financial materiality.
- GRIGRI Standards
Impact materiality.
- Department for Business and TradeUK SRS S1 and UK SRS S2
- Financial Conduct AuthorityPS26/19 — UK SRS on a comply-or-explain basis from 2027
- Financial Conduct AuthorityCP26/5 — the consultation the final rules finalise
- Financial Reporting CouncilISSA (UK) 5000
For voluntary use; periods from 15 December 2026.
- legislation.gov.ukCompanies Act 2006, section 414CB
- legislation.gov.ukSI 2018/1155 — SECR
- GHG Protocol (WRI/WBCSD)Corporate Accounting and Reporting Standard