Companies in scope 

  • Large undertakings revised to companies with >1000 employees (raised from 250 employees) AND EITHER turnover > €50 million OR balance sheet >€25 million.
  • The threshold for non-EU parent companies reporting has been raised from €150 million to €450 million in EU turnover.
  • Companies in the value chain of CSRD-regulated companies will be able to leverage voluntary guidance based on EFRAG’s published standards for SMEs. 

Reporting scope and criteria

  • Substantial reduction of the number of data points will be announced in the coming months.  
  • Sector-specific standards will be eliminated.
  • Principle of double materiality will be maintained (previous versions suggested this may go away). 
  • The Commission will publish targeted assurance guidance.
  • Proposal to move to reasonable assurance by October 2028 removed, keeping review to limited assurance.  

Assurance level

  • ‘Stop the clock’ – the Commission is proposing a 2 year-delay for large undertakings that have not yet started implementing CSRD and for listed SMEs (Waves 2 and 3). In effect, it means companies planning to report in 2026 and 2027 on their previous fiscal year would be able to report in 2028 and 2029.
  • The reporting timeline has not been delayed for third-country undertakings.

Timeline

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