Knowledge
Who has to report on sustainability, and from when?
Last reviewed: 1 September 2026 · next review planned for October 2026
The thresholds changed fundamentally in 2026, German transposition is — on the position documented here — still outstanding, and two versions of the reporting standards apply side by side. This page sets out what can be evidenced, and names what is open.
Under Directive (EU) 2026/470 (“Omnibus I”) both thresholds must be exceeded: more than 1,000 employees on average over the year and more than €450 million in net turnover. Being listed is no longer a criterion in its own right. Companies between 250 and 1,000 employees fall out of scope. Member States have until 19 March 2027 to transpose; application is generally foreseen for financial years beginning on or after 1 January 2027.
The numbers
Thresholds and deadlines at a glance.
| Instrument | Thresholds | Transposition / application | Legal basis |
|---|---|---|---|
| CSRD after Omnibus I | > 1,000 employees and > €450m net turnover | transposition by 19 Mar 2027, application generally for financial years beginning on or after 1 Jan 2027 | Directive (EU) 2026/470, Official Journal 26 Feb 2026 |
| Postponement of waves 2 and 3 | — | application dates deferred by two years; largely overtaken by Omnibus I | Directive (EU) 2025/794 |
| Reporting standards, 2023 version | — | still applicable for financial years beginning before 1 Jan 2027 | Delegated Regulation (EU) 2023/2772 |
| Reporting standards, revised version | about 61% fewer mandatory data points, roughly 75 instead of 91 disclosure requirements | mandatory for financial years beginning on or after 1 Jan 2027; a choice applies for earlier years | C(2026) 5010 final of 3 Jul 2026 |
| Supply chain due diligence | > 5,000 employees and > €1.5bn turnover | transposition by 26 Jul 2028, application from 26 Jul 2029 | Directive (EU) 2026/470 |
Germany
State of national transposition.
As long as the transposition act is not promulgated, the existing German provisions continue to apply — in particular sections 289b to 289e and 315b to 315c of the Commercial Code. The original CSRD transposition deadline expired on 6 July 2024 and was not met.
Contested among practitioners is the question, raised by the amendment, whether newly in-scope companies would have to report retrospectively for financial years from 1 January 2025. The standard setter and the profession have raised objections. This is one of the questions where an answer without a version and a date is worthless.
Where no obligation applies
The voluntary standard for smaller companies.
The new thresholds take many companies out of scope. The demand for sustainability data does not go away with them: it still comes from customers, banks and insurers — only without a legal framework to bound its extent.
For that situation a voluntary reporting standard is available, intended for companies up to 1,000 employees and substantially leaner than the full standards. Its practical value lies less in the reporting itself than in holding supply chain requests to a defined scope.
Frequently asked
From what size does a CSRD reporting obligation apply?
Under Directive (EU) 2026/470 both thresholds must be exceeded: more than 1,000 employees on average over the year and more than €450 million in net turnover. Being listed is no longer a criterion in its own right. Companies between 250 and 1,000 employees fall out of scope.
By when must Member States transpose the changes?
By 19 March 2027. Application is generally foreseen for financial years beginning on or after 1 January 2027.
Does the CSRD already apply in Germany?
On the position documented here, the German transposition act has not yet been promulgated. The government bill is before parliament as Bundestag document 21/1857 of 29 September 2025; an amendment carrying the new EU thresholds was tabled on 31 March 2026 and the public hearing in the legal affairs committee took place on 13 April 2026. Until promulgation, the existing German provisions continue to apply, in particular sections 289b to 289e and 315b to 315c of the Commercial Code. Check the current status before relying on this.
What applies to companies that fall out of scope?
A voluntary reporting standard is available for companies up to 1,000 employees. It is substantially leaner than the full sustainability reporting standards and is frequently asked for by business partners and banks even without a legal obligation.