JJurical
Sustainability2 credits

CSRD scope after Omnibus I — which wave are you in, and from which financial year?

Establish whether your undertaking falls under the sustainability reporting duty and which wave applies: an EU undertaking on employees and turnover, a non-EU undertaking on EU turnover with a subsidiary or branch, or an EU subsidiary of a non-EU parent with a possible exemption. With the first reporting year, the publication year and the transitional situations Omnibus I created.

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csrd-scope v1.0.0 · vintage 2026.1 · draft free
Example outcome
OutcomeWave 2
1,200 employees — threshold > 1,000Met
Net turnover € 520M — threshold > € 450MMet
First reporting year — publication 2028FY2027
sha256 a3f19c47e8b2d05f6c91a4e7d23b8f50…

Who it’s for

01Sustainability reporters and controllers who need to know whether and when they must produce a sustainability statement.
02Undertakings just outside the new thresholds that had started under the old regime and want to know what is now expected of them.
03Groups with a non-EU parent establishing whether the subsidiary must report itself or falls under the parent.

What the tool does

✓ Three routes: EU undertaking, non-EU undertaking with EU turnover, and EU subsidiary of a non-EU parent✓ Post-Omnibus I thresholds: more than 1,000 employees and more than € 450 million net turnover, both tested strictly✓ Nine possible outcomes, including the continuing first wave, exit from that wave, the second wave, the listed-SME opt-in and the exempt subsidiary✓ First reporting year and publication year per outcome, with the three-wave timeline and your own row flagged✓ A transition flag when you were in scope under the old regime but no longer under the new one✓ The eleven ESRS standards and seven preparation milestones as reference material for an in-scope outcome
01 — Form
Case and key figures — a handful of fields.
02 — Draft
Full outcome layout, free.
03 — Pay and receive
Via Mollie, VAT/VIES handled.
04 — Report
Certified PDF + public hash.

Out of scope is not the same as done

Omnibus I raised the thresholds substantially and moved the second wave’s first reporting year to FY2027. For many undertakings that means breathing room — but not the same kind for everyone. Those previously covered by the NFRD who now sit below the new threshold exit the first wave; those already in scope under the old CSRD regime land in a transitional situation. And those entirely out of scope but supplying an undertaking that is in scope will still face the data questions through the value chain.

The check distinguishes those situations explicitly rather than answering only yes or no, and adds the first reporting year and the publication year. For an in-scope outcome the report also carries the eleven ESRS standards and a preparation timeline as reference. Every report states the thresholds used, the tool version and the dataset vintage, so a reassessment on growth or at the next legislative change stays comparable.

Frequently asked questions about this tool

What happens exactly at the threshold?
The test is strict: you must be above it, on both counts. Exactly 1,000 employees or exactly € 450 million turnover is not more than the threshold and therefore yields no in-scope outcome. If you sit just below, the outcome depends on your answer to whether you were already in scope under the old regime — that determines whether you get a transitional outcome or simply fall out of scope.
When do I get a “transitional” outcome?
In two cases: if you were covered by the NFRD but do not meet the new threshold — then you exit the first wave — or if you indicate you were already in scope under the old CSRD regime while now sitting below the new threshold. On that second question you can also answer “?”, in which case the tool tests your figures against the old thresholds itself. Answer “no” and your figures are left out of that question entirely.
When does the listed-SME opt-in apply?
When you are listed and have between 10 and 249 employees, and were not previously covered by the NFRD — that question is answered earlier in the decision tree and takes precedence. Turnover plays no part in this band. The report states the outcome as an opt-in, that is a choice rather than an obligation.
How does the subsidiary exemption work?
The exemption applies when you claim it and confirm that the parent reports itself. If you are unsure about the latter, the tool grants no exemption. Note that the exemption is assessed before the own-threshold test, so a subsidiary that exceeds the threshold on its own is still reported as exempt when you confirm both. If you leave the figures blank on this route, the outcome lands on “out of scope” without a warning.
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CSRD scope after Omnibus I — which wave are you in, and from which financial year? — Jurical