Before investing resources into a comprehensive data collection campaign, you must accurately determine whether your company is legally required to report under the Corporate Sustainability Reporting Directive (CSRD). The February 2026 Omnibus Directive drastically altered the eligibility landscape, meaning many companies previously in scope are now exempt.
Evaluate the 2026 Omnibus Eligibility Thresholds
The Omnibus Simplification Package significantly raised the financial and headcount thresholds required to trigger a mandatory CSRD report. You must evaluate your company's metrics against these updated rules.
For EU-Based Companies
To fall under the mandatory reporting scope, an EU-based undertaking must now meet both of the following criteria on average during the financial year:
Headcount: More than 1, 000 employees.
Turnover: A worldwide net turnover exceeding €450 million.
Note: Unlike the original CSRD rules which looked at balance sheets and allowed companies to meet two out of three criteria, the Omnibus update strictly requires you to exceed both the 1, 000 employee and €450 million turnover marks to be mandated.
For Non-EU Parent Companies
If your ultimate parent company is headquartered outside of the European Union, the thresholds apply differently to capture significant economic activity within the European market.
Turnover: The non-EU ultimate parent must generate a net turnover of more than €450 million specifically within the EU.
Subsidiary Requirement: The parent must also have at least one subsidiary or branch located in the EU that meets the local EU thresholds or generates more than €40 million in local net turnover.
Determine Your Reporting Timeline
If your company meets the updated eligibility thresholds, you must identify your specific reporting wave to know exactly when your data collection must begin. The 2026 "stop-the-clock" provision delayed these deadlines.
Eligible EU Companies: You are required to collect sustainability data for the financial year starting on or after January 1, 2027. Your final audit and public disclosure will occur in 2028.
Eligible Non-EU Companies: You are required to collect data for the financial year starting on or after January 1, 2028. Your final audit and public disclosure will occur in 2029.
Strategy for Out-of-Scope Companies
If the Omnibus updates successfully removed your company from the mandatory CSRD scope, you must decide how to handle your sustainability strategy moving forward. Canceling your ESG efforts entirely is rarely the best business decision.
Assess Stakeholder Pressure: Even if the EU does not legally require your report, your largest B2B enterprise clients and financial investors likely still do. They need your emissions and social data to complete their own mandatory Scope 3 calculations.
Leverage the VSME Standard: The EU created the Voluntary SME (VSME) standard specifically for companies that fall below the €450 million threshold. Reporting against this simplified, non-mandatory standard protects your business relationships and satisfies enterprise vendor requirements without the crushing administrative burden of the full ESRS.
Transition Your Platform Workspace: If you have already started a project in the Greenly platform but are no longer in scope, contact your Project Manager to seamlessly transition your active framework from the full CSRD to the streamlined VSME or a custom investor report.