EU entity
An EU subsidiary may owe its own report.
CSRD · UK companies · after Omnibus I
CSRD UK
CSRD is not UK law, but a UK business may be reached through EU entities, a third-country group route or data requests.
Short answer
Does CSRD apply to UK companies? Only through the EU
CSRD is not UK law, but a UK business may be reached through EU entities, a third-country group route or data requests.
Four UK connections
Group route
A qualifying non-EU parent has a separate Article 40a route.
Data contribution
An EU parent or customer may request information.
Read the detailed guidance and evidence
CSRD reporting for UK companies is never a UK duty: it arrives through an EU subsidiary, through Article 40a of the Accounting Directive, through an EU parent, or through a customer’s data request.
Directive (EU) 2026/470, in force since 18 March 2026, moved every one of those thresholds.
This page tests each route against the amended text, so a UK board can see which one, if any, applies.
| Your position | What happens | From | Provision |
|---|---|---|---|
| You own an EU subsidiary above the thresholds | The subsidiary reports under ESRS in its own right | FY 2027 on the new test | Art 19a(1), 29a(1) |
| You are a UK group with large EU sales | An EU subsidiary or branch publishes a report on your whole group’s impacts | FY 2028 | Art 40a(1) |
| You are a UK subsidiary of an EU reporter | Your parent reports; you supply data into its group statement | The parent’s first year | Art 29a(1) |
| You supply an EU reporter | You receive data requests, capped if you have 1,000 staff or fewer | FY 2027 | Art 19a(3) |
The Corporate Sustainability Reporting Directive works by amending the EU Accounting Directive, so its rules live in the consolidated Accounting Directive, not in the 2022 text.
The content of the report comes from the European Sustainability Reporting Standards, first adopted as Delegated Regulation (EU) 2023/2772 and announced by the Commission on 31 July 2023.
The UK’s own standards are UK SRS S1 and S2, explained on what is UK SRS.
The directive itself, article by article, is on the EU CSRD, and the standards on the European Sustainability Reporting Standards.
Omnibus I
The CSRD thresholds, before and after
The revised EU reporting test needs more than 1,000 average employees and more than €450m net turnover, with application and transposition rules.
Two thresholds, both exceededRequirements and evidence
Module 01 / 03
Employees
More than 1,000; equality does not exceed the limb.
Module 02 / 03
Turnover
More than €450m; equality does not exceed the limb.
Module 03 / 03
Both
Passing only one limb does not satisfy the new EU test.
Read the detailed guidance and evidence
Directive (EU) 2026/470, the “Omnibus I” directive, was published on 26 February 2026 and entered into force on 18 March 2026.
It rewrote the CSRD’s entry test as two limbs that must both be exceeded: net turnover above €450 million and more than 1,000 employees on average.
That word matters: a company with exactly €450 million of turnover does not exceed it.
The Commission’s staff working document puts the effect at about 85% fewer companies, leaving about 6,753.
For financial years 2025 and 2026 a member state may exempt a company below €450 million or below 1,000 employees — “or”, where the scope test says “and” — so the relief reaches further than the test and differs by country.
The Council signed the package off on 24 February 2026, and the same directive narrowed the due-diligence regime, the CSDDD, to 5,000 employees and €1.5 billion.
| Test | Before Omnibus I | From FY 2027 |
|---|---|---|
| EU company | A “large undertaking” (Art 3(4)): exceeding two of €25m balance sheet, €50m turnover, 250 employees | More than 1,000 employees and more than €450m net turnover, both |
| Listed SMEs | A later wave | Removed; Article 29c deleted |
| Non-EU group, EU turnover | More than €150m | More than €450m in each of the last two years |
| Non-EU group, EU presence | A large EU subsidiary, or a branch above €40m | An EU subsidiary or branch above €200m |
Test your route
Which route reaches you, on your figures
An EU subsidiary is assessed under the relevant national implementation, including applicable 2025–26 options and the revised 2027 scope.
Test the EU entity and periodRequirements and evidence
Module 01 / 03
Entity
Identify the EU undertaking and any EU parent group.
Module 02 / 03
Period
Identify the financial year being reported.
Module 03 / 03
National implementation
Check the member state’s transposition and transitional choices.
Read the detailed guidance and evidence
An EU subsidiary of a UK group is tested exactly like any EU company: its own net turnover and average headcount, and, if it is itself a parent, its group’s.
Anyone who scoped a CSRD programme before 2026 should run the test again, because the population it produces is a fraction of the old one.
A subsidiary that reported as a public-interest entity in the first wave and sits below the new thresholds falls out from financial year 2027.
Whether it must still report for 2025 or 2026 is a question for the law of its member state; the EU’s register of transposition measures shows who has notified what.
Member states have until 19 March 2027 to transpose the Omnibus changes, so a missing national law today is not yet a late one.
Which CSRD route reaches you
Out of scopeNot caught by Article 40a on these figuresEU net turnover must exceed €450m in each of the last two consecutive financial years. One year above the line is not enough.Dir 2013/34/EU Art 40a(1), as amended by Dir (EU) 2026/470
Indicative, not advice.
Euro amounts are the directive’s; a sterling group converts at its own documented rate.
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UK groups
How UK-headquartered groups are caught: Article 40a
Article 40a assesses EU turnover and the relevant EU subsidiary or branch rather than applying the EU employee test to every UK parent.
The third-country route is separateRequirements and evidence
Module 01 / 03
Group turnover
EU turnover must exceed €450m in each of the last two years.
Module 02 / 03
EU connection
A qualifying EU subsidiary or branch exceeds €200m net turnover.
Module 03 / 03
First period
The route applies from financial years beginning in 2028.
Read the detailed guidance and evidence
Article 40a is the only route that attaches to a UK group as a group.
It is met when three things are true together.
The UK group’s net turnover generated in the EU exceeds €450 million in each of the last two consecutive financial years — EU sales, not worldwide sales.
It has an EU subsidiary or an EU branch whose own net turnover exceeded €200 million in the preceding financial year.
And the ultimate parent is governed by the law of a country outside the EU, which a UK parent is.
The obligation then sits on the EU subsidiary or branch, which must publish a report drawn up for the whole UK group, as EFRAG’s Basis for Conclusions explains (BC12, BC14).
The report covers impacts on people and the environment only; the directive excludes risks, opportunities, resilience and dependencies (BC15).
So a very large UK group with modest EU sales is outside, and a mid-sized one with concentrated EU revenue can be inside.
The thresholds are in euro, and a sterling group near €450 million should decide and record its exchange-rate basis before the test bites.
The standard for these reports is still being written, and EFRAG’s ESRS-40a project page carries an option to limit non-climate impacts to EU-related ones, which its own boards approved only with reservations.
- 23 Jul 202601
ESRS-40a exposure draft published
- 31 Oct 202602
EFRAG consultation closes
- Jan 202703
EFRAG technical advice to the Commission
- 1 Jan 202804
Article 40a financial years begin
- 202905
First Article 40a reports published
EFRAG ESRS-40a Basis for Conclusions BC1, BC11; Art 40a(1).
The other direction
UK subsidiaries of EU parents, and UK suppliers
A UK subsidiary of an EU reporter can contribute to its parent’s report without acquiring a separate UK CSRD reporting duty.
Data requests are not local dutiesRequirements and evidence
Module 01 / 03
Parent scope
Check whether the EU parent remains in scope.
Module 02 / 03
Consolidation
Understand which UK activities enter the group statement.
Module 03 / 03
Evidence
Retain methods, boundaries and the requested source records.
Read the detailed guidance and evidence
The reverse case is more common: a UK company owned by an EU group that reports under the CSRD.
The UK company has no CSRD duty of its own, but it sits inside the parent’s consolidated statement and will be asked for emissions, workforce and value-chain data.
The first question since 18 March 2026 is whether the EU parent is still in scope; if it is below the new thresholds, the group request may simply stop.
Where the parent stays in, the data it needs is set by its double materiality assessment, which can reach topics — pollution, biodiversity, value-chain workers — that UK SRS’s financial materiality judgement never would.
A UK company that only supplies an EU reporter is protected by the value-chain cap if it had an average of 1,000 employees or fewer in the preceding financial year.
The cap is drawn by Delegated Regulation (EU) 2026/1560, and it covers only the datapoints in its Annex II, not the whole voluntary standard.
UK firms already reporting under domestic regimes, listed on ESG reporting requirements in the UK, can usually serve both directions from one set of data.
| A request from an EU customer | Protected supplier (≤1,000 staff) |
|---|---|
| CSRD data within Annex II of 2026/1560 | Inside the cap; no statutory right to decline |
| CSRD data beyond Annex II | May be declined; the customer must flag it |
| Data for due diligence or other purposes | Outside the cap entirely |
Two regimes
CSRD and UK SRS for one UK group
ESRS uses double materiality, while UK SRS addresses sustainability-related financial information for primary users.
Different reporting lenses
Impact
ESRS considers the organisation’s impacts on people and the environment.
Financial
Both consider relevant financial risks and opportunities.
Local rules
Separate the EU statutory route from FCA comply-or-explain reporting.
Read the detailed guidance and evidence
| EU CSRD with ESRS | UK SRS | |
|---|---|---|
| Legal force | EU law for companies in scope | Voluntary standards; comply or explain for listed companies in five UKLR categories |
| Who is in | Size: more than 1,000 employees and €450m turnover; Article 40a for non-EU groups | Listing category, not size; no private-company threshold proposed |
| Materiality | Double: impact and financial | Single: financial, by cash flows, access to finance or cost of capital |
| Standards | Twelve ESRS | UK SRS S1 and S2 |
| Assurance | Limited assurance required | None required; listed companies state whether obtained |
| First year for a UK group | FY 2027 for an in-scope EU subsidiary; FY 2028 under Article 40a | Accounting periods beginning on or after 1 January 2027 for listed companies |
The deepest divide is materiality: the CSRD asks what the company does to the world as well as what the world does to the company.
UK SRS S1 asks only the second question, judged by the effect on cash flows, access to finance or cost of capital.
The FCA’s final rules of 30 September 2026 put listed companies in UKLR 6, 14, 15, 16 and 22 on comply or explain against UK SRS; the CP26/5 consultation had proposed mandatory UK SRS S2, and the final rules do not require it.
The full comparison is on UK SRS vs CSRD, the disclosure-level one on UK SRS vs ESRS, and the concept on double materiality.
What you will report against
The standards a UK group will actually use
The revised ESRS applies from 2027 financial years, with specific choices and reliefs for 2026.
- 2026 reporting01
Identify the permitted edition or relief option used.
- 10 Nov 202602
The revised delegated regulation enters into force.
- 2027 financial years03
Use the revised ESRS under the applicable rules.
Read the detailed guidance and evidence
An EU subsidiary reporting from financial year 2027 uses the revised ESRS, Delegated Regulation (EU) 2026/1563, which enters into force on 10 November 2026.
The Commission adopted the revision on 3 July 2026 and says it cuts mandatory datapoints by more than 60%.
A subsidiary reporting for 2026 chooses between the 2023 standards, the revised ones, or the 2023 standards with eight named reliefs, and must say which.
An Article 40a report uses neither: it will use ESRS-40a, built on the revised ESRS with the risk and opportunity disclosures removed.
Limited assurance is required, and Omnibus I deleted the move to reasonable assurance; EFRAG tracks the standards at its sustainability reporting hub.
Our dated account of the revision is EU adopts revised ESRS.
Next steps
What a UK group should do in the next six months
The third-country standard development and member-state implementation need their own status checks.
Separate enacted dates from draftsRequirements and evidence
Module 01 / 03
ESRS-40a
The consultation on the exposure draft closes on 31 October 2026.
Module 02 / 03
Transposition
Omnibus I transposition is due by 19 March 2027.
Module 03 / 03
Reporting route
Confirm the relevant entity, period and final instrument.
Read the detailed guidance and evidence
- List every EU subsidiary and branch, with net turnover and average headcount for the last two financial years.
- Test each against more than €450 million and more than 1,000 employees, and the group against Article 40a.
- For any subsidiary that reported in the first wave, ask its member state whether 2025 and 2026 reports are still due.
- If Article 40a could apply, read the ESRS-40a exposure draft and decide whether to respond by 31 October 2026.
- If you supply EU reporters, check your headcount against the cap and learn which requests it covers.
- If you are also UK-listed, plan UK SRS and ESRS from one data set, with the impact assessment as the ESRS-only work.
To talk a group’s position through, you can book a free 15-minute call.
Dates that do not move
31 October 2026 — the ESRS-40a consultation closes.
10 November 2026 — the revised ESRS enter into force.
19 March 2027 — member states must have transposed Omnibus I.
Frequently asked
Questions people ask
Does CSRD apply to UK companies?
Not as UK law: the UK left the EU and the CSRD was never part of UK law.
It reaches a UK business in four ways: an EU subsidiary that exceeds the thresholds reports in its own right; a UK group with more than €450 million of EU turnover in each of the last two years and an EU subsidiary or branch above €200 million is reported on under Article 40a from financial year 2028; a UK subsidiary of an EU reporter feeds its parent’s report; and a UK supplier receives data requests, limited by the value-chain cap where it has 1,000 employees or fewer.
What are the CSRD thresholds after Omnibus I?
From financial years beginning on or after 1 January 2027, an EU undertaking reports if it exceeds both a net turnover of €450 million and an average of 1,000 employees during the financial year; an EU parent applies the same test to its group.
The old large-undertaking test in Article 3(4) of the Accounting Directive — exceeding two of a €25 million balance sheet, €50 million turnover and 250 employees — no longer decides CSRD scope.
Does a company with 250 employees still have to report under CSRD?
Not on that basis.
Directive (EU) 2026/470 replaced the large-undertaking test with a cumulative one of more than 1,000 employees and more than €450 million net turnover, from financial years beginning on or after 1 January 2027.
For 2025 and 2026 some member states may exempt companies below either limb.
When do UK groups first report under CSRD?
Article 40a applies to financial years beginning on or after 1 January 2028, so the first reports are published in 2029.
The standard they report against, ESRS-40a, is still an exposure draft: EFRAG’s consultation closes on 31 October 2026 and its technical advice is due to the Commission in January 2027.
Who files the report for a UK group under Article 40a?
The EU subsidiary or EU branch publishes it, but the report is drawn up at the level of the ultimate UK parent or its group.
It covers the group’s impacts on people and the environment only; risks, opportunities, resilience and dependencies are excluded by the directive.
What does CSRD require on Scope 1, 2 and 3 emissions?
Where climate is material, revised ESRS E1 requires gross Scope 1 emissions, gross Scope 2 on both the location-based and market-based methods, and Scope 3 emissions from each significant category.
A UK group that also reports under UK SRS S2 will find that standard asks for location-based Scope 2, with market-based optional.
Can a UK supplier refuse an EU customer’s CSRD questionnaire?
In part.
A supplier with an average of 1,000 employees or fewer in the preceding financial year is a protected undertaking: for requests made for CSRD reporting it may decline information beyond the datapoints listed in Annex II of Delegated Regulation (EU) 2026/1560, and the customer must say which items exceed that.
The cap applies from financial years beginning on or after 1 January 2027 and does not cover requests made for other purposes, such as due diligence.
How does CSRD differ from UK SRS for a UK group?
CSRD is EU law requiring double materiality and twelve standards for companies above size thresholds.
UK SRS S1 and S2 are voluntary UK standards using single, financial materiality; under the FCA’s final rules, listed companies in UKLR 6, 14, 15, 16 and 22 report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
Reporting under one does not discharge the other.
Did Omnibus I change the CSDDD as well?
Yes.
Directive (EU) 2026/470 raised the Corporate Sustainability Due Diligence Directive’s thresholds to more than 5,000 employees and more than €1.5 billion net worldwide turnover, and deleted Article 22, the duty to adopt a climate transition plan.
Transition plan disclosure under ESRS E1 continues for companies reporting under the CSRD.
Fictional example
A questionnaire is not proof of scope
A fictional UK supplier receives an EU customer’s questionnaire and first identifies why the information is being requested.
A fictional UK supplierRequirements and evidence
Module 01 / 03
Purpose
Determine whether the request is for CSRD reporting or another purpose.
Module 02 / 03
Scope
Check whether a reporting duty applies to the supplier itself.
Module 03 / 03
Response
Check applicable value-chain protections and provide documented information.
Read the detailed guidance and evidence
This example illustrates a scope question and does not advise a real supplier to refuse information.
Preparation
Keep a group scope file
A scope file should show the legal entities, relevant turnover measures, financial years and applicable national implementation.
Make the group decision reviewableRequirements and evidence
Module 01 / 03
Entities
Map the UK parent, EU subsidiaries and branches.
Module 02 / 03
Figures
Record the relevant EU sales, entity turnover and employee measures.
Module 03 / 03
Conclusion
Identify the applicable route and the first reporting period.
Read the detailed guidance and evidence
This is an editorial record-keeping method, not an additional statutory filing.
Prepare the evidence
CSRD UK: 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
Applicability and timing
Check the entity, group, jurisdiction and reporting year against the current instrument.
- Stage 0202
Materiality
Document the assessment needed for the applicable reporting standard.
- Stage 0303
Value-chain requests
Scope the information requests and any applicable supplier protection.
- Stage 0404
Disclosure pack
Connect the applicable datapoints to controlled records and responsible owners.
- Stage 0505
Review and assurance
Check the applicable legal assurance route and implementation dates.
- Stage 0606
Publication
Resolve the report location, format and filing requirements for the entity.
Read the applicable instrument: Directive (EU) 2026/470 (Omnibus I), Official Journal record
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.
Trace the answerScope → evidence → review
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.
Checked against 19 sources fromEUR-LexEuropean CommissionCouncil of the EUEFRAGFinancial Conduct AuthorityDepartment for Business and Trade
- EUR-LexDirective (EU) 2026/470 (Omnibus I), Official Journal record
Published 26 February 2026, in force 18 March 2026.
- EUR-LexDirective (EU) 2026/470 — Arts 2(4)(a), 3(1)(c), 5(1) (full text)
The AND test for scope; the OR test for the national FY2025–26 option; transposition by 19 March 2027.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Arts 19a(1), 19a(3), 29a(1), 40a(1)
The scope test, the value-chain cap and the third-country test.
- EUR-LexDirective (EU) 2022/2464 — the CSRD as adopted
Its scope and wave dates have been replaced; cited for history only.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — ESRS Set 1
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS
In force 10 November 2026; applies to financial years from 1 January 2027.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 — the voluntary standard, Art 3(2) and Annex II
The value-chain cap, from financial years beginning on or after 1 January 2027.
- EUR-LexNational transposition measures for Directive (EU) 2026/470
Which member states have notified measures.
- European CommissionSWD(2026) 500 final
About 6,753 companies remain in scope; about 85% fewer.
- European CommissionCommission adopts revised sustainability reporting standards, 3 July 2026
- European CommissionCommission adopts European Sustainability Reporting Standards, 31 July 2023
- Council of the EUCouncil signs off simplification of sustainability reporting and due diligence requirements, 24 February 2026
- EFRAGESRS-40a Exposure Draft, Basis for Conclusions (BC1, BC6, BC11–BC15)
Group-level report published by the EU entity; impacts only; consultation to 31 October 2026.
- EFRAGSustainability reporting — ESRS development and revision
- EUR-LexDirective (EU) 2024/1760 (CSDDD), consolidated 18 March 2026
5,000 employees and €1.5bn; Article 22 deleted.
- Financial Conduct AuthorityPS26/19 — the final rules on UK SRS for listed companies
Comply or explain for UKLR 6, 14, 15, 16 and 22 from accounting periods beginning on or after 1 January 2027.
- Financial Conduct AuthorityCP26/5 — the consultation PS26/19 finalises (PDF)
Estimated around 600 listed companies affected — the consultation’s estimate.
- Department for Business and TradeUK SRS S1 and UK SRS S2, 25 February 2026
- Department for Business and TradeUK SRS S1 — ¶3, ¶18
Single, financial materiality.
Continue reading
Read next
EU law
EU CSRD
The directive itself: scope, assurance, the cap and transposition, provision by provision.
Standards
European Sustainability Reporting Standards
The revised ESRS as law, the FY2026 choice, and the UK SRS comparison.
Comparison
UK SRS vs CSRD
The two regimes side by side for a group that faces both.