CSRD · the directive itself
EU CSRD: the Corporate Sustainability Reporting Directive, article by article
The EU CSRD is the Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464, the law that makes a company in scope publish a sustainability statement in its management report.
It has no text of its own to follow: it amended the Accounting Directive, and Omnibus I amended that again in 2026.
This page reads the rules where they now sit, in the consolidated Accounting Directive of 18 March 2026.
The directive
What the EU CSRD is, and where its rules live
The CSRD does not stand alone: it amended the Accounting Directive, so the rules a company follows are articles of Directive 2013/34/EU.
A company in scope publishes a sustainability statement in its management report, written against the European Sustainability Reporting Standards and checked by an assurance provider.
The statement covers both directions of Article 19a(1): the undertaking’s impacts on sustainability matters, and how sustainability matters affect its development, performance and position.
Recital 29 of the directive as adopted names that pairing the double materiality perspective.
The as-adopted text still describes the old thresholds and wave dates, all of which have changed.
For scope and dates, read the consolidated Accounting Directive, never the 2022 text.
The CSRD replaced the reporting rules introduced by the Non-Financial Reporting Directive, which EUR-Lex still shows as in force because it was an amending directive that is spent rather than repealed.
| Accounting Directive | What it now says |
|---|---|
| Art 19a | An undertaking in scope reports on its impacts and on how sustainability matters affect it |
| Art 19a(3) | The value-chain cap for undertakings of 1,000 employees or fewer |
| Art 29a | The same duty for a parent, on a consolidated basis |
| Art 29b | The Commission adopts the reporting standards (ESRS) |
| Art 29ca | The Commission adopts standards for voluntary use |
| Art 29d | The single electronic reporting format |
| Art 34 | The limited assurance opinion |
| Art 40a | Reporting for non-EU groups through an EU entity |
Scope
Who is in scope of the EU CSRD after Omnibus I
Directive (EU) 2026/470, known as Omnibus I, was published on 26 February 2026 and entered into force on 18 March 2026.
It replaced the old size tests with one cumulative test: an undertaking is in scope when it exceeds a net turnover of €450 million and an average of 1,000 employees during the financial year.
Both limbs must be exceeded; meeting one is not enough.
The same test applies to an EU parent on a consolidated basis, for financial years beginning on or after 1 January 2027.
The listed-SME standard in Article 29c was deleted, along with the power to adopt sector-specific ESRS.
The Commission’s staff working document puts the remaining population at about 6,753 companies.
For financial years 2025 and 2026 each member state may exempt companies that do not exceed €450 million turnover or 1,000 employees, so whether an earlier report is still due depends on the country.
EU Taxonomy reporting under Article 8 of Regulation (EU) 2020/852 follows the same population by cross-reference, though the Omnibus did not amend the Taxonomy Regulation itself.
1,535 wave-one companies already reporting; 5,218 reporting for the first time.
Commission estimates.
Dates
The EU CSRD timeline, each date from its instrument
The dates that matter now, each read from the instrument that sets it rather than from a summary.
The revised standards, Delegated Regulation (EU) 2026/1563, enter into force on 10 November 2026 and apply to financial years beginning on or after 1 January 2027.
For financial year 2026 a company may use the 2023 standards, the revised ones, or the 2023 standards with eight named reliefs, and must state which.
The voluntary standard that defines the value-chain cap entered into force earlier, on 24 September 2026, on its own three-day clock.
Omnibus I has two transposition dates, and they are often swapped: 19 March 2027 for its reporting articles, and 26 July 2028 for its due-diligence article.
The due-diligence directive itself applies from 26 July 2029, with thresholds of 5,000 employees and €1.5 billion, and is a different regime.
- 16 Dec 2022CSRD published in the Official Journal
Directive (EU) 2022/2464.
- 22 Dec 2023ESRS Set 1 published
Delegated Regulation (EU) 2023/2772.
- 18 Mar 2026Omnibus I in force
The scope cut.
- 21 Sep 2026Revised ESRS and voluntary standard published
DR (EU) 2026/1563 and 2026/1560.
- 10 Nov 2026Revised ESRS in force
Application follows in 2027.
- 1 Jan 2027New scope and revised ESRS apply
Financial years beginning on or after.
- 19 Mar 2027Transposition deadline
Omnibus I Articles 1 to 3.
- 1 Jul 2027Limited assurance standards due
Commission delegated acts.
- 1 Jan 2028Article 40a financial years begin
First reports in 2029.
Article 40a
Non-EU groups under the EU CSRD
A group headquartered outside the EU is reached through Article 40a of the Accounting Directive.
The EU subsidiary or branch publishes a report drawn up for the whole group, which EFRAG notes is not an obligation placed on the parent itself.
The directive excludes risks, opportunities, resilience and dependencies from these reports, so they cover impacts only, as the ESRS-40a Basis for Conclusions sets out (BC3, BC15).
The standard for them, ESRS-40a, is still an exposure draft: EFRAG is consulting until 31 October 2026 and its technical advice is due in January 2027.
The deadline in Article 40b for the Commission to adopt it, 30 June 2026, has passed without adoption, and nothing in the directive attaches a consequence to that.
How this reaches a UK-headquartered group is on CSRD for UK companies.
| Article 40a(1) test | Threshold |
|---|---|
| EU net turnover of the non-EU group | More than €450m in each of the last two consecutive financial years |
| EU subsidiary or branch | More than €200m net turnover in the preceding financial year |
| Report covers | Impacts only, at the level of the ultimate parent |
| Applies to | Financial years beginning on or after 1 January 2028 |
Content
What companies report: the ESRS
The content of a CSRD report comes from the European Sustainability Reporting Standards, first adopted as Delegated Regulation (EU) 2023/2772.
There are twelve: two cross-cutting standards, ESRS 1 and ESRS 2, and ten topical ones, E1 to E5, S1 to S4 and G1.
ESRS 2 applies to every company in scope; a topical standard applies only where the company’s double materiality assessment finds its topic material.
The revised set published on 21 September 2026 kept the twelve, renamed E3 “Water”, and deleted every voluntary datapoint.
The standards read as law are on the European Sustainability Reporting Standards, and each standard’s contents on ESRS explained.
Assurance
Assurance under the CSRD: limited, and staying limited
The sustainability statement needs a limited assurance opinion, normally from the statutory auditor.
Recital (5) of Omnibus I removed the requirement to adopt reasonable assurance standards, to avoid an increase in the costs of assurance.
There is therefore no legislated move to a higher level.
Whether a firm other than the statutory auditor may give the opinion is a member-state choice, so the answer differs across the EU.
The assurer’s opinion must also respect a value-chain supplier’s right to decline information above the cap (Art 34(2a)).
The UK has no equivalent duty; the UK position is on UK SRS vs CSRD.
| Question | Answer in the directive |
|---|---|
| Level | Limited assurance (Art 34(1)) |
| What the opinion covers | Compliance with ESRS, the process to identify the information reported, and Taxonomy Art 8 disclosures |
| Who may give it | The statutory auditor; a member state may allow another auditor or an accredited independent provider (Art 34(3)–(4)) |
| Reasonable assurance | Power to adopt standards deleted by Omnibus I |
| EU assurance standards | Due by 1 July 2027, moved from 1 October 2026 |
The cap
The value-chain cap, as the directive writes it
Omnibus I protects smaller companies in a reporter’s value chain from open-ended data requests.
The line is set by Delegated Regulation (EU) 2026/1560, in force from 24 September 2026, whose cap covers only the datapoints listed in its Annex II.
The cap applies from financial years beginning on or after 1 January 2027.
It limits requests made for CSRD reporting only, as the Commission’s explanatory note of 6 May 2026 puts it; requests for due diligence or other purposes are outside it.
For the first three years a reporter that cannot get value-chain information explains its efforts; after that it uses the data it obtained or estimates.
The directive’s own cap is 1,000 employees; the due-diligence directive has a separate cap of 5,000, and the two are easily confused.
A protected undertaking has an average of 1,000 employees or fewer in the preceding financial year and sits in a reporter’s value chain.
It may decline CSRD requests beyond the voluntary standard, and a contract term to the contrary is not binding.
A reporter asking for more must say which items exceed the cap and that the supplier may refuse.
A reporter that takes nothing above the cap is deemed to have complied.
National law
Transposition: 27 answers, and nobody is late yet
| Member state | Measures notified for Omnibus I (as at 11 September 2026) |
|---|---|
| Belgium | 1 — amending its 2 December 2024 law, published 31 July 2026 |
| Croatia | 2 — published 29 April and 9 June 2026 |
| Finland | 2 — both dated 16 June 2026 |
| Poland | 1 — an Act of 27 February 2026, published 13 March 2026 |
| The other 23 | None notified |
The EU CSRD is a directive, so each member state writes it into national law.
For the Omnibus changes the deadline is 19 March 2027 (Art 5(1)), so a zero on the EUR-Lex register today is not lateness.
Until a member state transposes, the new national rules — including the value-chain cap — do not yet bind companies there, because a directive has no direct effect between private companies.
The delegated regulations need no transposition at all: they apply directly.
Check the law of each member state where the group has an in-scope entity, not only the directive.
A group working out what this means for a UK business can start at CSRD for UK companies, and the assessment behind any report at the double materiality assessment.
Support for a CSRD programme is described on CSRD consultancy, and you can book a free 15-minute call.
Frequently asked
Questions people ask
What is the EU CSRD?
The EU CSRD is the Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464.
It amended the EU Accounting Directive so that companies in scope publish a sustainability statement in their management report, written against the European Sustainability Reporting Standards and subject to limited assurance.
What does CSRD stand for?
Corporate Sustainability Reporting Directive.
“EU CSRD” is the same law; the prefix only distinguishes it from national rules and from UK regimes.
Who does the CSRD apply to now?
From financial years beginning on or after 1 January 2027, EU undertakings and EU parent groups that exceed both a net turnover of €450 million and an average of 1,000 employees during the financial year.
Directive (EU) 2026/470 set that cumulative test.
The Commission estimates about 6,753 companies remain in scope, roughly 85% fewer than before.
What is the CSRD timeline now?
Omnibus I entered into force on 18 March 2026.
The new scope and the revised ESRS apply to financial years beginning on or after 1 January 2027, so the first reports under both appear in 2028.
Member states must transpose the changes by 19 March 2027.
Non-EU groups report under Article 40a for financial years beginning on or after 1 January 2028, with first reports in 2029.
Does the CSRD apply to non-EU companies?
Yes, through Article 40a of the Accounting Directive.
A non-EU group is reached where its net turnover in the EU exceeds €450 million in each of the last two consecutive financial years and it has an EU subsidiary or branch with net turnover above €200 million.
The EU entity publishes a report on the whole group’s impacts from financial year 2028.
Does the CSRD require reasonable assurance?
No. The sustainability statement needs a limited assurance opinion, which also covers the process used to identify what is reported and the EU Taxonomy disclosures.
Omnibus I deleted the Commission’s power to adopt reasonable assurance standards, and the Commission must adopt limited assurance standards by 1 July 2027.
Can a small supplier refuse a CSRD data request?
A protected undertaking, one with an average of 1,000 employees or fewer in the preceding financial year, may decline requests made for CSRD reporting that go beyond the datapoints listed in Annex II of Delegated Regulation (EU) 2026/1560.
The reporter must say which items exceed the cap, and a contract term to the contrary is not binding.
Is the NFRD still in force?
EUR-Lex still shows the Non-Financial Reporting Directive, Directive 2014/95/EU, as in force, but it is spent rather than repealed: it was an amending directive, and the articles it inserted into the Accounting Directive have since been rewritten by the CSRD and by Omnibus I.
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 2013/34/EU (Accounting Directive), consolidated text of 18 March 2026
Arts 19a, 29a, 29b, 29ca, 29d, 34 and 40a as amended by the CSRD and Omnibus I — the operative text.
- EUR-LexDirective 2013/34/EU, consolidated — HTML view used for article quotations
Art 19a(1) both limbs; Art 19a(3) the value-chain cap; Art 34(1) assurance.
- EUR-LexDirective (EU) 2022/2464 — the Corporate Sustainability Reporting Directive, as adopted
OJ L 322, 16 December 2022. Correct for recitals; its scope and wave dates are replaced.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
Published 26 February 2026, in force 18 March 2026.
- EUR-LexDirective (EU) 2026/470 — Arts 1(3), 2, 3(1)(c), 4, 5(1), 6 and recitals (5), (24) (full text)
Reasonable assurance deleted; limited assurance standards by 1 July 2027; mark-up suspended; transposition dates.
- EUR-LexNational transposition measures for Directive (EU) 2026/470
Read 11 September 2026: Belgium 1, Croatia 2, Poland 1, Finland 2; the other 23 member states none.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — ESRS Set 1
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS, Articles 1–3
In force 10 November 2026; applies to financial years from 1 January 2027; the FY2026 choice in Art 2.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 — the voluntary standard, Arts 3–4 and Annex II
In force 24 September 2026; the value-chain cap from financial years beginning on or after 1 January 2027.
- European CommissionSWD(2026) 500 final — staff working document
About 6,753 companies in scope: 1,535 already reporting, 5,218 new; about 85% fewer.
- European CommissionAdditional explanatory information regarding the value chain cap, 6 May 2026
The cap applies only in the context of CSRD reporting.
- EFRAGESRS-40a Exposure Draft — Basis for Conclusions
Third-country reports from financial years starting 1 January 2028; impacts only; advice due January 2027.
- EUR-LexDirective 2014/95/EU — the Non-Financial Reporting Directive
Shown on EUR-Lex as in force; spent, not repealed.
- EUR-LexRegulation (EU) 2020/852 (EU Taxonomy), Art 8
Taxonomy reporting follows Arts 19a and 29a by cross-reference.
- EUR-LexDirective (EU) 2024/1760 (CSDDD), consolidated 18 March 2026
Separate thresholds; application from 26 July 2029.