Most of the sustainability reporting thresholds in circulation are **out of date**. Directive (EU) 2026/470, known as Omnibus I, substantially narrowed the CSRD scope.
The current rule
Undertakings that, on their balance sheet date, exceed **both EUR 450 million in net turnover and an average of 1,000 employees** must include sustainability information in their management report. Note the **AND**: exceeding only one threshold does not create the obligation.
The obligation previously foreseen for **listed SMEs (former Article 5(2)(c)) was deleted.**
First reporting applies to financial years starting on or after **1 January 2027**.
Below the threshold: you do not report — but the questions still arrive
This is where it matters. A company below the threshold is **not required to report**; but if it sits in the value chain of a customer that is in scope, data requests will come. Most non-EU suppliers meet the CSRD this way for the first time.
The directive provides a protection here: sustainability reporting standards must take account of the difficulty of gathering information from value-chain actors, especially from those **not subject** to the reporting requirements. A cap is foreseen on what may be requested from undertakings that do not exceed **1,000 employees**.
The practical consequence: a customer in scope cannot request unlimited data from you. Whether an incoming request fits within that cap is a question you are entitled to ask.
The ESRS standards
The content of the reporting is set by the European Sustainability Reporting Standards; the delegated regulation in force lists **12 standards** (ESRS 1 and 2 are general, the rest cover environmental, social and governance topics).
Why working from old thresholds is dangerous
An assessment made with superseded thresholds sells an obligation to a company that does not have one. That is not only unnecessary cost but a misstatement risk. A threshold looks like a number, but it depends on **which version of the text it was read from**.
How Nechh Eco-Report handles it
The Eco-Report CSRD module reads the thresholds from the Omnibus I text and assesses the value-chain protection and the out-of-scope case separately. Legislative change is tracked by machine. Eco-Report is a preparation tool; it does not replace an audit or an official declaration.
Source: Directive (EU) 2022/2464 (CSRD), Directive (EU) 2026/470 (Omnibus I) and Delegated Regulation (EU) 2023/2772 (ESRS), EUR-Lex.
Publication note: This content is general information; it is not legal advice, a conformity assessment or a company-specific compliance evaluation. The final determination rests on the official text and, where needed, legal advice.