CSRD Checker — Methodology

Omnibus I scope test

An EU undertaking is in CSRD scope under the Omnibus I amendments only if it satisfies BOTH the employee threshold AND the net-turnover threshold for a large undertaking:

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

The Omnibus I amendment (Directive (EU) 2026/470, amending the CSRD — Directive (EU) 2022/2464) raised the EU large-undertaking gate to >€450M net turnover AND >1,000 employees — BOTH required (the turnover figure alone never triggers scope). A separate THIRD-COUNTRY test brings a non-EU undertaking into scope on more than €450M of EU net turnover PLUS a qualifying EU subsidiary or branch (see Phase 3).

CSRD is an EU directive: it reaches a UK entity only through an EU nexus (an EU subsidiary or branch, or a non-EU parent with EU-based turnover above the third-country threshold), so most UK SMEs are outside mandatory scope — for them the voluntary VSME standard is the right path. Listed status no longer creates a separate test: listed and unlisted undertakings face the identical size gate, and listed SMEs are exempt. The Omnibus I amendment is not yet transposed into national law (transposition deadline 19 March 2027), so a positive result means “CSRD may apply — assess your EU nexus”, not that it is enacted and applicable to you.

The three-layer applicability engine

Three-phase reporting timeline

1. Phase 1 (Large PIEs, >500 staff, already in scope before Omnibus I): First report due 1 January 2025 (FY 2024 data) — this wave has already passed.
2. Phase 2 (Large Undertakings under the Omnibus I conjunctive threshold): First report due 1 January 2028 (FY 2027 data), delayed by Omnibus I from the original FY 2025 deadline.
3. Phase 3 (Non-EU / third-country undertakings): First report due 2029 (FY 2028 data) for non-EU undertakings with EU net turnover above €450M and a qualifying EU subsidiary or branch. (The original listed-SME Phase 3 was removed by Omnibus I — listed SMEs are now exempt, not deferred.)

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 under Phase 1 (already reported, FY 2024), in scope from FY 2027 (Phase 2 — first report due 2028), in scope from FY 2028 (Phase 3, non-EU third-country undertakings — first report due 2029), 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?

Omnibus I is an amendment TO the CSRD — Directive (EU) 2026/470, which amends Directive (EU) 2022/2464 (the CSRD). It narrows scope to a conjunctive size gate: an EU undertaking is in mandatory scope only if it exceeds BOTH the employee threshold (more than 1,000 staff) AND the net-turnover threshold (more than €450M). Both limbs are required — the turnover figure alone never triggers scope, and a company that satisfies only one limb is out of mandatory scope.

Are listed SMEs still in scope under Omnibus I?

No. Under the Omnibus I amendment (Directive (EU) 2026/470) listed SMEs are exempt and listing status no longer creates a separate route into CSRD scope. Every EU undertaking — listed or not — is in mandatory scope only if it exceeds BOTH limbs of the conjunctive size gate (more than 1,000 employees AND more than €450M net turnover), or it meets the separate third-country rule (a non-EU parent with more than €450M EU net turnover AND a qualifying EU subsidiary or branch). The original CSRD listed-SME wave has been removed, not merely delayed. Always confirm against the directive text in the Official Journal.

Which directive applies?

The CSRD is Directive (EU) 2022/2464; it 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). Directive (EU) 2026/470 (“Omnibus I”) is a later amendment TO the CSRD — it is not itself “the CSRD”. ESRS (European Sustainability Reporting Standards) — the actual disclosure framework — is established by Commission Delegated Regulation (EU) 2023/2772.

Does the CSRD apply to a UK company?

CSRD is an EU directive, so it does not automatically bind a UK entity. It reaches a UK company only through an EU nexus — an EU subsidiary or branch, or a non-EU parent generating more than €450M of EU-based net turnover. Most UK-only SMEs are outside mandatory scope. The Omnibus I amendment is not yet transposed into national law (transposition deadline 19 March 2027), so treat a positive result as “CSRD may apply — assess your EU nexus and take qualified advice”, not a confirmation that it is enacted and applicable to you.

What if my company is just under one threshold?

Track growth carefully. The Omnibus I size gate is conjunctive: above BOTH limbs or out. Companies trending toward both thresholds 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, and is the recommended path for most UK SMEs.