CSRD Checker — Methodology

Omnibus I scope test

A company is in CSRD scope under the Omnibus I amendments if it satisfies BOTH of the following thresholds:

• Employees ≥ 1,000 (annual average)
• Net turnover ≥ €450M

The previous CSRD-original rule (2 of 3 criteria from employees / turnover / balance sheet) is superseded by this stricter conjunction. Listed status no longer creates a separate test under Omnibus I, but listed SMEs continue to face phased reporting obligations under the delayed Phase 3 timeline.

Three-phase reporting timeline

1. Phase 1 (Large PIEs, >500 staff, already in scope): First report due 1 January 2025 (FY 2024 data).
2. Phase 2 (Large Undertakings): First report due 1 January 2026 (FY 2025 data).
3. Phase 3 (Listed SMEs): Originally 1 January 2027 (FY 2026 data); Omnibus I delays by two years.

What our checker does

The free-tool form collects employee count, net turnover, and listing status. The classifier returns one of four outcomes: in scope today (Phase 1), in scope from FY 2025 (Phase 2), in scope from FY 2026 (Phase 3 — subject to Omnibus I delay), or out of scope (with a cross-link to our VSME Materiality Light tool). The email follow-up sends a five-stage nurture sequence with deadline calculator, framework comparison, and preparation checklist.

Frequently asked

What changed in Omnibus I?

The Omnibus I amendments — enacted as Directive (EU) 2026/470, in force 18 March 2026 — narrow CSRD scope: an undertaking is now only in scope if it exceeds BOTH the employee threshold (≥1,000 staff) AND the turnover threshold (≥€450M). The previous '2 of 3 criteria' rule from the original CSRD text is replaced by this stricter conjunction. Companies that satisfy only one threshold drop out of scope.

Are listed SMEs still in scope under Omnibus I?

Listed SMEs were originally Phase 3 (FY 2026 reporting). Omnibus I delays Phase 3 by two years and tightens the SME size definition. Treat 'listed SME' as still in scope but with reporting deferred — confirm against the Omnibus I directive text (Directive (EU) 2026/470, in force 18 March 2026) in the Official Journal.

Which directive applies?

Directive (EU) 2022/2464 (CSRD) amends the Accounting Directive (2013/34/EU), the Transparency Directive (2004/109/EC), the Audit Directive (2006/43/EC) and the Audit Regulation (537/2014). ESRS (European Sustainability Reporting Standards) — the actual disclosure framework — is established by Commission Delegated Regulation (EU) 2023/2772.

What if my company is just under one threshold?

Track growth carefully. Under Omnibus I, CSRD scope is binary: above both thresholds or below. Companies trending toward the threshold should begin double-materiality preparation now — first-time reporters typically need 12-18 months from kick-off to publish a CSRD-compliant sustainability statement.

Does this checker also tell me about VSME?

Yes — the result includes a cross-link to our VSME Materiality Light tool. The Voluntary SME Standard (VSME) is the EU's proportional reporting framework for companies out of CSRD scope; it shares the double-materiality structure but with fewer mandatory ESRS topics.