Which companies are directly subject to CSRD reporting obligations?
Companies directly subject to CSRD reporting requirements are those that exceed at least two of the three thresholds: more than 250 employees, over €50 million in turnover or a balance sheet total exceeding €25 million. The EU Omnibus Package 2026 raised these thresholds, meaning significantly fewer enterprises than originally anticipated are subject to mandatory ESG reporting.
The Three CSRD Criteria
A company is subject to CSRD reporting requirements if it meets at least two of the following three criteria: more than 250 employees, more than €50 million in net turnover, or a balance sheet total exceeding €25 million. Capital market-oriented SMEs (listed companies) are subject to separate ESG disclosure regulations.
Amendments under the 2026 Omnibus Package
The EU Omnibus Package 2026 has raised the thresholds for CSRD alignment, exempting numerous companies that would have originally been required to report from 2026. Consequently, significantly fewer than the initially estimated 15,000 businesses in Germany are directly affected by the sustainability reporting directive.
The Indirect Impact on SMEs Remains
Even with fewer companies subject to direct CSRD reporting requirements, the remaining large corporations must still report on their supply chain sustainability — and are increasingly demanding robust ESG data from their SME suppliers. The VSME standard serves as the EU-recommended framework for SME ESG reporting.
Which companies are required to report under the CSRD? Sustainability reporting thresholds, Omnibus 2026 amendments, and the implications for SMEs in the supply chain.