Most of the sustainability reporting thresholds in circulation are out of date. Directive (EU) 2026/470, known as Omnibus I, substantially narrowed the CSRD scope.
The current rule
Undertakings that, on their balance sheet date, exceed both EUR 450 million in net turnover and an average of 1,000 employees must include sustainability information in their management report. Note the AND: exceeding only one threshold does not create the obligation.
The obligation previously foreseen for listed SMEs (former Article 5(2)(c)) was deleted.
First reporting applies to financial years starting on or after 1 January 2027.
Below the threshold: you do not report — but the questions still arrive
This is where it matters. A company below the threshold is not required to report; but if it sits in the value chain of a customer that is in scope, data requests will come. Most non-EU suppliers meet the CSRD this way for the first time.
The directive provides a protection here: sustainability reporting standards must take account of the difficulty of gathering information from value-chain actors, especially from those not subject to the reporting requirements. A cap is foreseen on what may be requested from undertakings that do not exceed 1,000 employees.
The practical consequence: a customer in scope cannot request unlimited data from you. Whether an incoming request fits within that cap is a question you are entitled to ask.
The ESRS standards
The content of the reporting is set by the European Sustainability Reporting Standards; the delegated regulation in force lists 12 standards (ESRS 1 and 2 are general, the rest cover environmental, social and governance topics).
Why working from old thresholds is dangerous
An assessment made with superseded thresholds sells an obligation to a company that does not have one. That is not only unnecessary cost but a misstatement risk. A threshold looks like a number, but it depends on which version of the text it was read from.
How Nechh Eco-Report handles it
The Eco-Report CSRD module reads the thresholds from the Omnibus I text and assesses the value-chain protection and the out-of-scope case separately. Legislative change is tracked by machine. Eco-Report is a preparation tool; it does not replace an audit or an official declaration.
Source: Directive (EU) 2022/2464 (CSRD), Directive (EU) 2026/470 (Omnibus I) and Delegated Regulation (EU) 2023/2772 (ESRS), EUR-Lex.
Publication note: This content is general information; it is not legal advice, a conformity assessment or a company-specific compliance evaluation. The final determination rests on the official text and, where needed, legal advice.