The CSRD Scope Just Changed Again: Are You Still In, or Are You Out?

Table of Contents

• Two Years of Preparation, Then the Rules Changed
• What the Omnibus I Package Actually Changed
• Who Remains In Scope for 2026
• Who Just Moved Out of Scope
• The Specific Case of Wave 1
• Why Verify Now, Not at Year-End
• The Risk Runs Both Ways
• Quick Verification Checklist
• FAQ
• Regard d’Expert
• Références

Two Years of Preparation, Then the Rules Changed

A finance team launches a CSRD compliance program in 2024, hires dedicated staff, engages an external audit firm for double materiality assessment. By late 2025, the rules change. Scope narrows sharply, and the company that had been preparing for two years discovers it may no longer be covered, or worse, no longer knows exactly where it stands.

What the Omnibus I Package Actually Changed

In December 2025, the European Parliament approved revised sustainability rules as part of the Omnibus I simplification package, significantly narrowing CSRD scope. Thresholds were revised: only companies with more than 1,000 employees and more than €450 million in annual net turnover remain in mandatory scope. Listed SMEs and financial holding companies are no longer automatically in scope, though existing transition plans remain applicable for CSRD.

The 250-employee, €25M threshold is gone — replaced by 1,000 employees and €450M in turnover.

Who Remains In Scope for 2026

Companies already subject to CSRD that remain within the revised thresholds must continue publishing annually. For these companies, the next report is due in 2026, covering fiscal year 2025 data. There’s no relief for this group, the only thing that changed is the threshold reference, not the reporting obligation itself.

Who Just Moved Out of Scope

Wave 2, covering large EU companies not previously subject to NFRD (based on the 250+ employee criterion), was originally scheduled to begin reporting in 2026. That timeline has been pushed to 2028. In practice, thousands of companies actively preparing their first CSRD report just gained two additional years, provided they don’t exceed the newly raised thresholds.

The Specific Case of Wave 1

Original Wave 1 companies, those already reporting under CSRD before the revisions, did not receive the relief granted to other reporting waves. If they remain within the revised thresholds, they must continue publishing annually, with the next report due in 2026 for fiscal year 2025, then in 2027 for fiscal year 2026.

For Wave 1 companies, there’s no relief — continuous reporting remains mandatory.

Why Verify Now, Not at Year-End

A regulatory scope change of this magnitude creates risk in both directions. A company that wrongly assumes it’s out of scope exposes itself to a disclosure failure if it still exceeds the revised thresholds in a given fiscal year. A company that keeps investing resources in a program that’s become non-mandatory ties up budget and headcount that could be redeployed elsewhere.

The Risk Runs Both Ways

Transposition of EU rules into national law remains uneven across member states as of early 2026, Germany, France, the Netherlands, and several others transposed on time, while some Southern and Eastern European member states lagged. For multinational groups, group-level and subsidiary-level obligations may follow slightly different national timelines, further complicating verification of actual status.

Quick Verification Checklist

• Does the company’s relevant consolidated headcount exceed 1,000 employees?
• Does annual net turnover exceed €450 million?
• Was the company already subject to CSRD before the Omnibus I revisions (Wave 1)?
• Has transposition status been verified in every significant country of operation?

FAQ

Can a company that falls out of scope keep reporting voluntarily?
Yes, and many companies choose to do so to meet growing investor expectations for ESG transparency, even without a legal requirement.

Are the revised thresholds final?
The agreement includes review clauses that could broaden requirements again in the future, the situation remains evolving, not fixed.

What happens if a company hovers around the new thresholds year to year?
Annual status verification becomes necessary rather than a one-time assessment, thresholds are measured fiscal year by fiscal year.

Have the ESRS standards themselves changed?
A revision of the ESRS is expected from the European Commission in the first half of 2026, likely applying to fiscal year 2027 reporting.

Regard d’Expert

Having supported data governance and regulatory compliance programs across multi-country contexts, I consistently see this kind of scope change create more uncertainty than the absence of a rule would. The priority isn’t guessing whether you’re covered, it’s verifying factually, fiscal year by fiscal year.

Written by Steeve Vignissy, Senior Digital Transformation Consultant at Notoriti.

👉 Contact Notoriti to verify your CSRD compliance status.

Références

• Normative, CSRD Explained (2026): Requirements, Scope & How to Comply, May 2026
• BDO, CSRD Revised Scope, Timelines, and Requirements, April 2026
• Socious, CSRD Compliance Timeline 2026: Wave 1, 2, 3, 4 Deadlines, April 2026