CSRD 2026 Update: New Reporting Thresholds, Timeline Delay & What Companies Must Do Now
- Anna Neumann
- Apr 5
- 2 min read
Recent regulatory developments around the Corporate Sustainability Reporting Directive (CSRD), including the EU’s “Omnibus” simplification proposals, bring a clear message: the scope is narrowing, but expectations for companies in scope remain high.
Who Needs to Report?
Under the updated direction, CSRD will focus primarily on large companies:
EU companies must meet both:
More than €450 million net turnover at the balance sheet date, and
More than 1,000 employees (average over the financial year)
Non-EU companies must meet:
At least €450 million net turnover generated in the EU, and
Additionally, one of the following:
An EU subsidiary with more than €200 million turnover, or
An EU branch with more than €200 million turnover
A key relief: listed SMEs are no longer expected to fall under mandatory CSRD reporting, significantly reducing the number of affected companies in EU by ca 80-85%.
What Does “1,000 Employees” Really Mean?
The threshold is calculated based on headcounts, not FTEs.
This includes:
Part-time employees
Marginal employees
Employees on probation
Employees on maternity leave
Excluded are:
Managing directors
Apprentices and interns
Employees on parental leave
This definition can materially impact your eligibility—many companies underestimate their actual headcount.
Not sure if you’re in scope? A structured materiality assessment can clarify your position and priorities. The Caribou Materiality Assessment Module helps you quickly identify what really matters—before investing in strategic implementation and reporting.
Timeline Update: “Stop-the-Clock”
The EU’s “stop-the-clock” decision postpones CSRD implementation by two years:
First-wave companies continue reporting as planned
All others will start in 2028 (for the 2027 financial year)
While this delay offers breathing room, it should not be seen as a reason to wait. Companies that start early will have a clear advantage.
What About Reporting Standards?
Another major shift: sector-specific ESRS standards are no longer expected. Instead, EFRAG may issue non-binding guidance.
In the meantime, companies are increasingly aligning with:
SASB (Sustainability Accounting Standards Board)
GRI (Global Reporting Initiative)
These frameworks remain highly relevant for building a robust and audit-ready reporting structure.
What Should Companies Do Now?
The most effective starting point is not data collection—it’s focus.
Companies should:
Conduct a double materiality assessment to identify their most relevant ESG topics with related impacts, risks, and opportunities
Based on double-materiality results prioritize what truly matters and create strategic priorities
Build sustainability strategy-related processes instead of trying to cover everything at once
Create data-system for data collection and implement functioning sustainability governance
A well-executed materiality assessment doesn’t just ensure compliance—it prevents wasted resources and accelerates your entire CSRD journey.
Start with clarity, not complexity. The Caribou Materiality Assessment Module enables fast, structured, and audit-ready assessments—helping you focus on the ESG topics that truly drive impact and compliance.
Bottom Line
CSRD is becoming more targeted—but also more strategic. Companies in scope will need to demonstrate not only compliance, but clear prioritization and high-quality ESG data.
Those who act now—starting with double materiality assessment —will be best positioned to stay efficient, compliant, and competitive.
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