Which companies are directly subject to CSRD reporting obligations?
Since the EU Omnibus Package 2026, only companies with more than 1,000 employees and more than €450 million in net turnover are directly subject to CSRD reporting requirements. The former thresholds (250 employees, €50 million in turnover, €25 million in balance sheet total) have thus been raised significantly, meaning far fewer enterprises than originally anticipated are subject to mandatory ESG reporting.
The CSRD Criteria after the Omnibus Package
An EU company is subject to CSRD reporting requirements if it meets both criteria: an average of more than 1,000 employees and a net turnover exceeding €450 million. Until the Omnibus Package, two of three criteria were enough: more than 250 employees, a net turnover exceeding €50 million, a balance sheet total of more than €25 million. Listed small and medium-sized enterprises (SMEs) no longer fall under the CSRD.
Changes Introduced by the Omnibus Package 2026
The EU Omnibus Package 2026 raised the thresholds for CSRD compliance, exempting numerous companies from direct reporting obligations that would have otherwise applied from 2026. Consequently, the number of directly affected companies in Germany is significantly lower than the originally estimated 15,000.
The Trickle-Down Effect on SMEs Remains
Despite fewer companies being directly subject to CSRD, the indirect impact remains significant. Large enterprises with mandatory ESG reporting obligations must still report on their supply chain sustainability, thereby requesting ESG data from their SME suppliers. The VS standard is the reporting format for SMEs adopted by the European Commission.
Which companies are required to report under the CSRD? Sustainability reporting thresholds, Omnibus 2026 amendments, and the implications for SMEs in the supply chain.