EU Revised ESRS Delegated Act Finalised — CSRD Scope Narrowed to 1,000+ Employees and €450M Turnover

The European Commission adopted the final revised European Sustainability Reporting Standards (ESRS) Delegated Act on July 3, 2026, following the Omnibus I Directive that entered into force in March 2026. The revised CSRD framework raises mandatory reporting thresholds dramatically: companies are now in scope only if they exceed 1,000 employees AND €450 million net annual turnover — a dual-criteria requirement that is expected to remove approximately 90% of the roughly 50,000 companies originally covered. Listed SMEs have been removed from scope entirely; Wave 2 companies first report in 2028 on fiscal year 2027; non-EU parent companies first report in 2029. However, the revised ESRS standards are substantively more rigorous within the narrowed scope — materiality-based disclosure, double materiality assessment, and limited assurance requirements remain mandatory. For US companies with EU subsidiaries or EU turnover exceeding €450 million, the new standards become effective November 20, 2026, and apply to financial years beginning January 1, 2027. Cooley's analysis confirms the revised ESRS are now effectively final and cannot be amended — preparation must begin now.