CSRD thresholds

This guide focuses on a decision record rather than replacing the CSRD overview.

Record the legal entity, group perimeter, reporting year and applicable Member State before starting a numerical comparison.

Exactly €450 million or exactly 1,000 average employees does not exceed the respective threshold, so avoid the loose shorthand 1,000-plus where equality matters Article 2 point 4.

These invented boundary examples illustrate only the amended numerical screen and do not determine any real company’s legal reporting position.

The conclusion field should say which test was met rather than recording a bare yes or no.

Keep the evidence for turnover and employee measurement alongside the applicable national-law review.

Group membership alone does not establish a subsidiary exemption because the relevant conditions, reporting basis and publication arrangements must be checked Article 2 points 4 and 5.

Do not add a 1,000-employee requirement to Article 40a, because that is a different route from Articles 19a and 29a.

A UK group can therefore need separate records for an EU subsidiary’s own duty and the eventual third-country report publication route.

The CSRD UK guide explains the wider UK-group context.

A group with substantial EU sales is not automatically within Article 40a without checking the qualifying-presence limb.

Article 40a reporting begins for FY2028, while the dedicated ESRS-40a content standard remains an exposure draft as at 26 October 2026 Article 5(2)(d) EFRAG consultation release.

The fictional Northstar case illustrates the numerical limbs only and does not establish scope, timing, equivalence or exemption for an actual group.

Record whether the figures relate to the third-country group or individual undertaking and why that level is appropriate.

Do not use worldwide turnover in place of Union turnover.

The 2025 stop-the-clock directive and the later substantive Omnibus must be read together rather than relying on the original CSRD wave dates Directive 2025/794 Original CSRD.

For a third-country-parent exemption, EU Taxonomy information covering the exempted EU undertaking’s activities remains part of the conditions Article 2 point 4 Regulation 2020/852, Article 8.

Financial holding undertakings also have specific provisions that must not be generalised to every investment group Article 2 points 5 and 13.

Taxonomy simplification is governed by its own delegated regulation and does not create a universal CSRD scope percentage Regulation 2026/73.

The cap covers only the datapoints specified in Annex II of the voluntary-standard regulation, rather than every possible voluntary disclosure Regulation 2026/1560, Article 3 and Annex II.

Record contractual and other-law considerations separately rather than assuming the cap cancels every request.

The VSME guide explains the voluntary reporting route.

The Commission’s July announcement concerns the standards package rather than a replacement for the scope instrument Commission adoption release.

Use CSRD software or CSRD consultancy briefs to request the actual scope decision record before building the reporting workflow.

The original fictional examples on this page illustrate boundary logic rather than offering a company-specific legal determination.

Preserve earlier conclusions and record what changed instead of overwriting the history.