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CSRD & ESRS Reporting

Updated for the July 2026 revised ESRS, Omnibus I scope changes, and the voluntary standard

What this preview covers

  • How Omnibus I transformed CSRD scope and which companies remain in scope
  • The revised ESRS adopted on 3 July 2026 and the datapoint reductions
  • Double materiality: the core assessment methodology
  • The voluntary standard and value-chain cap
  • Assurance, digital reporting, and what the full course covers
Preview: ~25 minutes | Full course: 40 hours
The Framework

CSRD in 2026: What Has Changed

~2.5 min read

The Corporate Sustainability Reporting Directive (CSRD) was adopted in 2022 to transform sustainability disclosure from a voluntary exercise into a regulated, audited, standardised reporting obligation. However, the framework has undergone significant changes since its original design.

Omnibus I: Scope Significantly Narrowed

The Omnibus I amendments (entered into force 18 March 2026) raised CSRD scope thresholds from the original 250 employees / €50M turnover to:

More than 1,000 employees AND more than €450 million net annual turnover.

Both conditions must be exceeded. This significantly reduces the number of companies subject to mandatory CSRD reporting compared to the original ~50,000 estimate. The original waves two (all large companies) and three (listed SMEs) have been removed for companies below the new thresholds. Wave-one companies that still meet the revised thresholds continue reporting; those falling below may be exempted by their member state for FY2025 and FY2026, and will fall outside mandatory scope from FY2027 onward.

>1,000
Employee Threshold
After Omnibus I
>€450M
Turnover Threshold
Both must be exceeded
12
ESRS Standards
Revised July 2026
>60%
Mandatory Datapoints Reduced
Revised ESRS
Third-Country Undertakings

Where the ultimate parent undertaking is governed by the law of a third country, it is in scope when its consolidated net turnover generated in the Union exceeds €450 million, provided it has at least one qualifying EU subsidiary (meeting the revised size thresholds) or an EU branch with net turnover exceeding €200 million. The subsidiary and branch tests are alternative gateways. Reporting is at the group level through the qualifying EU entity. (Amended Accounting Directive, Article 40a.)

Regulatory position verified as of 29 July 2026. Directive (EU) 2026/470 (Omnibus I) entered into force on 18 March 2026. The revised ESRS were adopted on 3 July 2026 and are subject to a two-month scrutiny period (extendable by two months).
Timeline

From Four Waves to a Narrower Scope

~2.5 min read

The original CSRD envisaged a four-phase rollout covering approximately 50,000 companies. Two legislative interventions changed this significantly.

ElementOriginal CSRD (2022)After Omnibus I (March 2026)
Wave 1 (in scope)Large public-interest entities (NFRD companies), 500+ employees. Reports from 2025 (FY2024).Companies still exceeding the revised thresholds (>1,000 employees AND >€450M turnover) continue reporting.
Wave 1 (out of scope)Same original population.Companies falling below the revised thresholds: member states may exempt them for financial years beginning between 1 Jan 2025 and 31 Dec 2026. From FY2027 onward, they fall outside mandatory scope. They may continue reporting voluntarily.
Wave 2All large companies: 250+ employees, >€50M revenue, or >€25M assets. Reports from 2026.Stop-the-clock (Directive (EU) 2025/794) postponed by 2 years. Omnibus I then raised thresholds to >1,000 employees AND >€450M turnover, removing most wave-2 companies from scope.
Wave 3Listed SMEs. Reports from 2027 (opt-out to 2028).Removed from mandatory scope. Listed SMEs are no longer required to report under CSRD.
Third-country undertakingsUltimate parent outside EU with >€150M net EU revenue and an EU subsidiary or branch. Reports from 2029.The ultimate parent (governed by third-country law) must have consolidated net turnover generated in the Union exceeding €450 million, and at least one EU subsidiary meeting the revised size thresholds or an EU branch with net turnover exceeding €200 million. Subsidiary and branch tests are alternative gateways. Reporting is through the qualifying EU entity. (Amended Accounting Directive, Article 40a.)
Voluntary reportingNot formally addressed.Companies falling out of scope may continue reporting voluntarily using the voluntary standard adopted on 3 July 2026.
Member-State Transposition

EU member states must transpose the Omnibus I amendments into national law within the applicable transposition period. Until transposition, national requirements may differ from the directive text. Companies should verify the position under their national legislation.

Revised Standards

Revised ESRS: Adopted 3 July 2026

~2.5 min read

On 3 July 2026, the European Commission adopted revised European Sustainability Reporting Standards through delegated acts. The revision delivers significant simplification:

>60%
Mandatory Datapoints Reduced
>70%
Total Datapoints Reduced
>30%
Expected Cost Reduction per Company

The revised standards are shorter, clearer, and include new flexibilities. They streamline key processes including materiality assessment and reporting. The 12 ESRS standards remain organised into four groups:

GroupStandardsCoverage
Cross-cuttingESRS 1, ESRS 2General requirements and mandatory disclosures
EnvironmentalE1–E5Climate, pollution, water, biodiversity, circular economy
SocialS1–S4Own workforce, value chain workers, communities, consumers
GovernanceG1Business conduct, ethics, anti-corruption
Scrutiny Period: Not Yet Applicable

The revised ESRS delegated acts are subject to a two-month scrutiny period by the European Parliament and Council, which can be extended by a further two months. The revised standards become applicable only after this period is completed without objection. As of July 2026, the scrutiny period is running.

What This Means for Reporting Companies

Companies currently in scope (wave-one entities) should prepare for the revised standards while recognising that they are not yet formally applicable. The full course covers both the original 2023 ESRS and the July 2026 revisions, explaining what has changed and how to transition.

New Framework

Voluntary Standard & Value-Chain Cap

~2 min read

Alongside the revised ESRS, the Commission adopted a voluntary reporting standard for smaller companies outside CSRD scope. This addresses a critical gap in the framework.

The Voluntary Reporting Standard

The voluntary standard provides a single, proportionate reference framework that smaller companies can use to report sustainability information. Its primary purpose is to help companies that are part of larger companies’ value chains respond to sustainability-information requests without facing disproportionate reporting burdens.

This is distinct from EFRAG’s earlier VSME (Voluntary Sustainability Reporting Standard for non-listed Micro, Small, and Medium-Sized Enterprises) technical advice, although the voluntary standard adopted on 3 July 2026 builds on that work.

The Value-Chain Cap

The adopted framework establishes a value-chain cap: once applicable (after the scrutiny period is completed), companies subject to CSRD will not be permitted to require value-chain companies to provide more sustainability information than what is covered by the voluntary standard, subject to the applicable legal provisions. Until the voluntary standard becomes legally applicable, the cap is not yet operative. Once in force, this will be a significant protection for smaller suppliers facing sustainability-data requests from larger customers.

The full course covers the voluntary standard in detail, including how to use it as a value-chain supplier and how to structure data requests as a CSRD-scoped company.

Preview: Module 2

Double Materiality Assessment

~2 min read

Double materiality is the foundation of ESRS reporting. A sustainability topic is material if it is material from the impact perspective, the financial perspective, or both.

Illustrative Scenario: Water in a Textile Supply Chain

Impact materiality: A textile company’s cotton supply chain in water-stressed regions contributes to water depletion affecting local communities (negative, actual impact).

Financial materiality: Drought-driven raw material scarcity creates procurement cost risk and potential supply disruption.

In this case, water is material from both perspectives. However, a topic could be material from only one perspective — for example, a financial risk from emerging regulation without a corresponding direct environmental impact from the company’s own operations.

Preview: Module 6

Assurance & Digital Reporting

~2 min read

CSRD requires sustainability reports to undergo independent third-party assurance for the first time in EU corporate reporting.

Current Assurance Requirements

Limited assurance is the current requirement for CSRD sustainability reports. Any move to reasonable assurance is contingent on: (a) a Commission feasibility assessment, (b) adoption of specific assurance standards, and (c) further legislative steps. There is no automatic transition to reasonable assurance at a fixed date.

The IAASB issued ISSA 5000 (General Requirements for Sustainability Assurance Engagements) in December 2024. It is effective for assurance engagements on sustainability information for periods beginning on or after 15 December 2026, with early adoption encouraged. ISSA 5000 covers both mandatory and voluntary sustainability-assurance engagements and sets a global baseline. However, it does not automatically become the statutory EU assurance standard — separate EU adoption and national implementation are required.

Digital Reporting and XBRL

EFRAG has developed an ESRS XBRL taxonomy for digital tagging of sustainability reports. The exact mandatory-tagging requirements depend on the Commission’s adoption of the digital taxonomy through delegated acts and the applicable ESEF (European Single Electronic Format) instruments. Companies should monitor the applicable legal position for their reporting period rather than assuming universal XBRL filing obligations are already in force.

Full Course

What the Full Course Covers

~2 min read

The full course provides 40 hours of practitioner-level training across 6 modules, updated for the July 2026 framework.

Module 1 — CSRD Framework
CSRD scope, Omnibus I, stop-the-clock, and the July 2026 revised ESRS
  • Original CSRD vs Omnibus I scope
  • Revised thresholds and non-EU rules
  • Voluntary standard and value-chain cap
  • Transition provisions
Module 2 — Double Materiality
End-to-end materiality assessment methodology
  • Impact and financial materiality
  • IRO identification
  • Stakeholder engagement
  • Practical DMA exercise
Module 3 — Environmental (E1–E5)
Climate, pollution, water, biodiversity, circular economy
  • Climate transition plans
  • Scope 1–3 emissions
  • EU Taxonomy alignment
  • Changes in the revised ESRS
Module 4 — Social & Governance
S1–S4 and G1 standard-by-standard
  • Own workforce and value chain workers
  • Communities and consumers
  • Business conduct and ethics
  • CSDDD integration
Module 5 — Data Collection & Reporting
Building reporting infrastructure for the revised ESRS
  • Revised datapoint requirements
  • Data collection architecture
  • Gap analysis methodology
  • Digital reporting and XBRL status
Module 6 — Assurance & Implementation
Limited assurance readiness and change management
  • What auditors look for
  • Internal controls for sustainability reporting
  • Cross-functional mobilisation
  • Implementation roadmap
FAQ

Frequently Asked Questions

~2 min read
References

Primary Sources

~1 min read

Primary Sources

Regulatory position verified as of 29 July 2026. The revised ESRS and voluntary-standard delegated acts adopted on 3 July 2026 are subject to a two-month scrutiny period (extendable by two months). The Omnibus I amendments (Directive (EU) 2026/470) entered into force on 18 March 2026. ISSA 5000 is effective for periods beginning on or after 15 December 2026.

Start the Full Course

CSRD & ESRS Reporting — Certificate of Completion
  • Updated for July 2026: Omnibus I scope, revised ESRS, voluntary standard, and value-chain cap
  • 40 hours of practitioner-level training across 6 modules
  • All 12 ESRS standards covered standard-by-standard with practical exercises
  • Double materiality simulation — end-to-end DMA exercise
  • Data collection and reporting: gap analysis, architecture, and digital reporting
  • Certificate of Completion upon passing all module assessments

Enrol in the Full Course

Comprehensive CSRD and ESRS training, updated for the July 2026 framework.

£399 | $479
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Full course starts with
Module 1: CSRD Framework & Scope
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