What is the CSRD and who does it still apply to?
The CSRD requires large companies to report on sustainability under fixed European standards, in the management report and reviewed by an auditor. Since the Omnibus package of March 2026 the group of companies in scope is far smaller: the directive now applies only from an average of more than 1,000 employees and more than EUR 450 million net turnover, with first reporting on financial years beginning on or after 1 January 2027.
The short answer
CSRD stands for Corporate Sustainability Reporting Directive. It makes sustainability information part of annual reporting: not a separate sustainability report, but a chapter in the management report, prepared under the European reporting standards and accompanied by an assurance opinion. The thinking behind it is that financiers, customers and regulators should be able to compare and rely on sustainability information in the same way as financial figures.
Who does the CSRD apply to after Omnibus?
The original system had four waves, with thresholds that would in time also capture medium-sized and listed small companies. That has been abandoned. After Omnibus I:
| Company | Threshold | First reporting |
|---|---|---|
| EU company | More than 1,000 employees on average and more than EUR 450 million net turnover | Financial year beginning on or after 1 January 2027 |
| Non-EU company | More than EUR 450 million turnover in the EU, with a subsidiary or branch of significance | Financial year 2028 |
| Listed small and medium-sized company | Outside the directive | No obligation |
Both thresholds must be met: employees and turnover. A company with 1,200 employees and EUR 300 million turnover therefore falls outside. Companies already reporting under the first wave keep their existing obligation, but do benefit from the relaxations.
What must the report contain?
The CSRD works on the principle of double materiality. You report on two sides of the same coin:
- Impact outwards. What effects your company has on people and the environment, in its own operations and in the value chain.
- Financial effects inwards. Which sustainability risks and opportunities affect your revenue, costs, assets and access to capital.
Which topics actually enter the report is determined by a materiality assessment. That assessment is not a formality: it is the document an auditor and later a regulator will fall back on when they ask why a topic was or was not addressed.
What assurance is required?
The sustainability report is reviewed with limited assurance. The previously announced step to reasonable assurance was dropped under Omnibus. That saves cost, but changes nothing fundamental: the information must be traceable to a source, and that source must exist at the moment it is requested.
And if you fall outside the scope?
This is the question asked most often in practice, and the answer is less reassuring than it appears. Companies outside the direct scope still get the CSRD on their plate through the chain: a customer or financier in scope needs data on your emissions, your working conditions or your material use.
Omnibus has put a brake on this. Companies with no more than 1,000 employees on average are protected: they may not be asked for more information than the voluntary reporting standard for SMEs prescribes. A contractual provision going further is unenforceable. That is a usable argument in negotiations on purchasing conditions and finance documentation, and it is worth knowing before you sign.
Dutch implementation
The amendments must be transposed into Dutch law by 19 March 2027 at the latest. Dutch implementing legislation had not been completed when Omnibus was adopted and is now being aligned with the new framework. In practice: work to the European thresholds and timeline, and watch the national elaboration for the detail on the management report and the audit.
What to do now
- Establish whether you meet both thresholds, on a consolidated basis and over time. A growing company moves into scope by itself.
- If you are in scope, start with the materiality assessment. It is the longest step and determines the rest.
- If you are out of scope, map who in your chain does report and what they will ask of you.
- Review your contracts for information obligations that go beyond the voluntary SME standard.
- Keep advertising claims strictly separate from reporting data. From 27 September 2026, stricter rules against greenwashing apply.
Frequently asked questions
Does the CSRD apply to a Dutch subsidiary of a foreign group?
A subsidiary may be exempt if it is included in the consolidated sustainability report of the parent, provided that report meets the European requirements. For non-EU groups a separate regime applies with a threshold of EUR 450 million EU turnover.
Is the CSRD the same as the CSDDD?
No. The CSRD is about reporting; the CSDDD is about acting: actually investigating and addressing adverse impacts in the chain. After Omnibus the CSDDD has much higher thresholds, applies from 5,000 employees and EUR 1.5 billion turnover, and only starts to apply from 26 July 2029.
What happens if we do not report, or report late?
The sustainability report forms part of the management report. Its absence or inaccuracy affects the filing obligation and may lead to directors’ liability, alongside enforcement by the regulator.
Questions about your CSRD obligation?
Law & More assesses whether your company falls within the CSRD, supports the materiality assessment from a legal perspective and reviews chain contracts for information obligations that go further than permitted. Please feel free to get in touch for an initial discussion.
