EU CSRD Omnibus Final: Scope Cut from ~50,000 to ~5,000 Companies — >1,000 Employees AND >€450M Turnover; ESRS Simplification Delegated Acts Adopted July 3

The CSRD omnibus cycle is complete. Directive (EU) 2026/470 — in force March 18, 2026, transposition due March 19, 2027 — established the final post-omnibus scope threshold: mandatory CSRD applies only to companies with more than 1,000 employees AND more than €450 million net turnover (a cumulative AND test replacing the old two-of-three size criteria). The Commission estimates this cuts the number of in-scope companies from approximately 50,000 to approximately 5,000 — an 80% reduction. Listed SMEs are entirely removed from mandatory scope; the former Wave 3 listed-SME category is replaced by the voluntary VSME standard. Third-country groups are caught with more than €450 million EU net turnover (up from €150 million) plus an EU subsidiary that is a large undertaking or an EU branch with more than €200 million turnover (up from €40 million). Newly in-scope companies report for FY2027, first reports in 2028; non-EU groups start FY2028, reporting in 2029. Wave 1 companies that already report and remain above thresholds continue. On July 3, 2026, the Commission adopted two ESRS simplification delegated acts: one amending Delegated Regulation (EU) 2023/2772 (simplifying certain ESRS datapoints) and one establishing voluntary sustainability reporting standards for undertakings protected by the value-chain cap. For ESG practice leaders: the in-scope company universe has shrunk dramatically, but the companies that remain in scope — the largest EU companies and largest non-EU groups with significant EU revenue — are core clients for most major ESG practices. The value-chain cap protection (in-scope companies may not demand data beyond the VSME standard from suppliers with fewer than 1,000 employees) is the provision most relevant for supply chain counsel.