Who has to comply with CSRD?

After Omnibus I, the directive applies to EU companies with more than 1,000 employees and more than €450M in net turnover. It also covers non-EU groups generating over €450M in EU turnover for two consecutive financial years, with an EU subsidiary or branch generating over €200M. Listed SMEs, originally in scope, were removed by Omnibus I.

What is double materiality and why does it matter?

Double materiality requires reporting on two dimensions: how sustainability issues affect the business (financial materiality, the outside-in view), and how the business affects people and the environment (impact materiality, the inside-out view). The double materiality assessment determines which topics enter the report and which are excluded, and is the most scrutinized part of CSRD compliance under limited assurance.

What does a CSRD report contain?

A CSRD report covers four areas: environment (climate, pollution, water, biodiversity, and circular economy), social (workforce, value chain workers, affected communities, and consumers), governance (business conduct), and cross-cutting disclosures covering strategy, materiality, targets, policies, and actions. Reports sit inside the management report, are digitally tagged for machine readability, and are subject to limited assurance.

Does CSRD require external audit?

Yes. Limited assurance is required from year one. Omnibus I removed the previously planned upgrade to reasonable assurance, making limited assurance the permanent requirement. The European Commission must adopt limited assurance standards by July 1, 2027.

What are the consequences of non-compliance with CSRD?

Penalties are set by each member state during transposition and vary across jurisdictions. The pattern across early-transposing countries includes administrative fines, public naming, and personal liability for directors in serious cases. Non-compliant or qualified reports also carry commercial consequences, as banks, customers, and investors increasingly screen for CSRD-aligned disclosure.

What changes for Wave 1 companies under Omnibus I?

The reporting obligation continues for companies that still meet the revised thresholds. The primary change is the data point burden: the simplified ESRS, due by September 18, 2026, is expected to reduce the number of required disclosures compared to the original 2023 standards.

What options exist for companies below the CSRD threshold whose customers request ESG data?

The voluntary VSME standard provides a lighter reporting framework that is credible with customers, banks, and insurers, and constitutes a defensible response to procurement questionnaires. Companies using the VSME standard can transition to full ESRS reporting if their size or structure brings them into CSRD scope in future reporting cycles.

CSRD

Corporate Sustainability Reporting Directive (CSRD)

The Corporate Sustainability Reporting Directive requires large EU companies to report on sustainability impacts and risks under double materiality principles, following European Sustainability Reporting Standards. Omnibus I narrowed scope in March 2026 to companies with more than 1,000 employees and more than €450M net turnover. Manage double materiality assessments, data collection, and ESRS reporting on one platform with the osapiens HUB.

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Next deadline

1 January 2027: start of the first reporting year under the revised CSRD.

If you're newly in scope after Omnibus I, this is when your data collection clock starts. First report due in 2028.

Regulation timeline

18. March 2026

Omnibus I Directive enters into force, narrowing scope to companies with more than 1,000 employees and more than €450M net turnover and extending timelines for newly in-scope companies by two years.

2027

First financial year covered for newly in-scope companies under the post-Omnibus CSRD scope.

1. July 2027

The European Commission must adopt limited assurance standards by this date. Limited assurance is the permanent requirement for CSRD reports following Omnibus I.

2025

Former Wave 1 companies publish first CSRD reports covering FY 2024 data.

18. September 2026

The European Commission must publish the simplified ESRS by this date, replacing the original 2023 standards with a reduced set of disclosure requirements.

19. March 2027

Member states must transpose Omnibus I into national law by this date.

2028

First CSRD reports published by newly in-scope companies, covering FY 2027 data.

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2025

2025
Former Wave 1 companies publish first CSRD reports covering FY 2024 data.
2026

18. March 2026
Omnibus I Directive enters into force, narrowing scope to companies with more than 1,000 employees and more than €450M net turnover and extending timelines for newly in-scope companies by two years.
18. September 2026
The European Commission must publish the simplified ESRS by this date, replacing the original 2023 standards with a reduced set of disclosure requirements.
2027

2027
First financial year covered for newly in-scope companies under the post-Omnibus CSRD scope.
19. March 2027
Member states must transpose Omnibus I into national law by this date.
1. July 2027
The European Commission must adopt limited assurance standards by this date. Limited assurance is the permanent requirement for CSRD reports following Omnibus I.
2028

2028
First CSRD reports published by newly in-scope companies, covering FY 2027 data.

osapiens Guide

CSRD after Omnibus I: A Practical Guide for Second-Wave Companies

Omnibus I has reshaped the CSRD landscape. Many companies preparing for the second reporting wave now need to reassess their scope status.

This guide covers the revised thresholds, timelines, and reporting requirements, plus the steps to prepare your governance, materiality assessment, and data processes.

What you will learn:

Whether your company remains in scope
What Omnibus I changed on thresholds, timing, and the ESRS
What double materiality and limited assurance require
How to map data sources and responsibilities
How to build a scalable annual reporting process

Download the guide to clarify your CSRD position and plan your next steps.

What the regulation requires

CSRD reports follow the European Sustainability Reporting Standards across four disclosure areas: environment, social, governance, and cross-cutting disclosures covering strategy, materiality, targets, policies, and actions. Reports sit inside the management report, must be digitally tagged for machine readability, and are subject to limited assurance from year one.

Where CSRD implementation breaks down

A double materiality assessment is an audited, evidence-backed methodology

The assessment determines which sustainability topics enter the report and which are excluded. An underdocumented or poorly scoped assessment produces either over-reporting, which wastes resources, or under-reporting, which creates assurance failure risk.

ESRS data points are scattered across ERP, energy, HR, and supplier systems

Scope 3 emissions, supplier social metrics, energy by site, and board diversity data rarely share a format or a system. Consolidating them for a single report requires a structured data collection layer.

Limited assurance applies from year one

Every disclosure requires a documented source, a control, and an audit trail. Auditors apply the same evidentiary standards to sustainability reporting that they apply to financial statements.

CSRD requirements continue to evolve

Simplified ESRS, national transposition variances, and regulatory overlaps with the CSDDD, EU Taxonomy, and CBAM mean that the compliance picture is changing between reporting cycles. Obligations confirmed in one quarter may be revised or extended before the report is filed.

OSAPIENS HUB FOR DISCLOSURES AND REPORTING

Double materiality, data collection, and ESRS reporting on one platform

The osapiens HUB covers the full CSRD compliance workflow, from the double materiality assessment through ESRS data collection to assurance-ready reporting, built on the same data layer as CSDDD, EU Taxonomy, and CBAM obligations.

Build a defensible double materiality assessment on a pre-mapped ESRS foundation

The osapiens IRO Library provides a pre-built, ESRS-mapped foundation for impacts, risks, and opportunities. The Materiality Matrix and interactive dashboards support prioritization, defense, and revision as inputs change.

Connect CSRD, CSDDD, EU Taxonomy, and CBAM to one shared data layer

ESRS data points, REST API integrations with ERP and energy systems, and pre-built reporting structures mean data collected for one obligation is available across all four. A figure entered once does not require re-entry for a separate regulatory workflow.

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