e2morrowESG Report · CSRD
Since 18 March 2026, the threshold is more than 1,000 employees and more than €450 million in turnover, at the same time.
The Omnibus I package, published in February 2026, substantially changed the CSRD's thresholds and deadlines. The directive has been in force since 18 March 2026, with mandatory national transposition by 19 March 2027 and a simplified revision of the ESRS due by 18 September 2026.
Since 18 March 2026, the threshold is more than 1,000 employees and more than €450 million in net turnover. Third-country undertakings follow their own threshold: more than €450M in turnover generated in the EU, with an EU subsidiary or branch above €200M.
Both criteria — employees and turnover — must be met at the same time; the balance-sheet criterion was dropped.
It depends on the wave your company falls into — from those already reporting since 2025 to those only joining in 2029.
| Wave | Who | Year | Filed |
|---|---|---|---|
| 01 · Former NFRD | PIEs >500 employees | 2024 | Since 2025 |
| 02 · Large companies | Above the new threshold | 2027 | 2028 |
| 03 · Listed SMEs | Listed, regulated market | 2028 | 2029 |
| 04 · Third-country undertakings | Own threshold (EU) | 2028 | 2029 |
They define what to report, how to measure it, and how to structure disclosure — cross-cutting and topical standards across the three ESG pillars. A simplified revision is under way, due by 18 September 2026.
Each topic is assessed in two directions: how the company affects people and the environment, and how ESG risks affect its financial value. It only needs to be relevant in one of the two to belong in the report.
How the company affects people and the environment.
How ESG risks affect the company's value.
An ESRS-compliant report needs real data per metric, with a source and an owner identified — not a questionnaire filled in from memory. It also needs traceability: knowing who changed what, and when. That traceability is what makes it auditable.
Only if it exceeds, at the same time, more than 1,000 employees and more than €450 million in net turnover (EU companies). Smaller companies can report voluntarily, or may be asked for data by clients or lenders who are already in scope.
It no longer applies on that single criterion. The Omnibus package, in force since March 2026, replaced the former test (2 of 3 criteria, including more than 250 employees) with a single, higher threshold: more than 1,000 employees and more than €450M in turnover, at the same time.
It depends on the wave it falls into. Organisations already reporting since 2025 (former NFRD) remain in scope, with a possible transitional exemption for those that fall outside the new scope. Large companies newly in scope report on financial year 2027, filed in 2028.
Yes. The Omnibus directive is in force, but Member States only have to transpose it into national law by March 2027, and the simplified revision of the ESRS is only finalised in September 2026. Confirm your specific position with your auditor before making final decisions.
We organise data collection by ESRS module, calculate the ESG Health Score and keep an immutable audit log of every change. The narrative for each section is drafted by AI from the numbers your team has recorded — never invented.
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