Following the Omnibus revision through Directive (EU) 2026/470 (opens in a new tab), CSRD applies to companies with more than 1,000 employees and net turnover above €450 million. The first reporting year differs by situation. Companies that have reported since financial year 2024 carry on, while companies newly in scope start with financial year 2027. This article sets out who has to report and when, what the sustainability statement is, and what a company can concretely do now.
What the Omnibus revision changed
The original CSRD timeline has been revised in two steps. Directive (EU) 2025/794 (opens in a new tab), the “stop the clock” track, has been in force since 17 April 2025 and is what sets financial year 2027 as the first reporting year for companies not yet reporting. Directive (EU) 2026/470 then reduced the population of reporting companies by raising the thresholds.
Dutch transposition is running late and no implementing act is in force. Bill 36678 is in written preparation in parliament, and the amendment incorporating Directive (EU) 2026/470 is still awaited. Until that law arrives, the exemption for financial years 2025 and 2026 that the Dutch government intends to use does not exist either.
Who CSRD applies to now
The reporting obligation applies to companies that meet both criteria:
- more than 1,000 employees, and
- net turnover above €450 million.
The first reporting year depends on the situation.
Already obliged since financial year 2024. Large public-interest entities with more than 500 employees keep their obligation for financial years 2025 and 2026, still under the 2023 ESRS. Release for those two years is available only to companies that stay below the new thresholds, and only where the member state has enacted the exemption in law. A company comfortably above both thresholds reports without interruption.
Newly in scope. Large companies that meet the two criteria and were not previously reporting prepare their first sustainability statement over financial year 2027.
EU subsidiaries and branches of non-EU groups. For qualifying non-EU groups the obligation starts with financial year 2028.
Companies below the thresholds fall outside the obligation in principle. One carve-out reaches EU subsidiaries of foreign groups. Where a non-EU parent generated more than €450 million EU turnover in each of the two preceding financial years and the subsidiary or branch more than €200 million, the obligation sits from financial year 2028 with that subsidiary or branch, which publishes the parent’s report.
Listed SMEs are permanently outside the mandatory regime. Voluntary reporting remains possible — more on that below.
What the sustainability statement is
Companies in scope include a sustainability statement in the management report. The statement is prepared under the ESRS (European Sustainability Reporting Standards): standardised reporting standards that define which sustainability information is reported, and how.
The standards themselves have been revised. On 3 July 2026 the Commission adopted a new version with over 60% fewer mandatory datapoints, which applies from financial year 2027 once parliamentary scrutiny is complete. For financial years 2025 and 2026 the 2023 ESRS remain in force.
The important point: the sustainability statement is not a separate document alongside the annual report, but part of it. Sustainability information and financial reporting land in the same reporting process — with the same demands on consistency and verifiability.
ESRS XBRL tagging
The directive provides for digital tagging of the sustainability statement using the ESRS XBRL taxonomy, once the accompanying technical standard applies. The principle mirrors ESEF for the financial statements: the statement becomes machine-readable, so regulators, investors and analysts can process the information in structured form.
Sustainability data thus follows the same route financial data already travelled: from free text and PDF to structured, tagged information. Teams designing their reporting process now are well advised to build tagging in as a standard step, rather than bolting it on at the end.
Assurance: limited assurance
The sustainability statement is subject to auditor assurance, at a limited level (limited assurance). The auditor also looks at the process behind the figures and statements, and once mark-up is required the opinion covers that too. Traceability is therefore not a nice-to-have: every figure and every statement in the report must trace back to a source.
Below the thresholds: voluntary reporting with VSME
For companies below the thresholds the obligation lapses from financial year 2027 at the latest — but the questions often do not. Banks, insurers and large customers in the value chain ask non-obligated companies for sustainability information too. For that situation there is the voluntary VSME standard: a lighter, standardised way of reporting for companies outside the CSRD scope. Reporting voluntarily against a standard answers those information requests better than an in-house format.
What to do now
The dates are known, but the first reporting year is not in the future for everyone. Four concrete actions:
- Establish the scope. Test the company against the two criteria (more than 1,000 employees and €450 million net turnover), at the right consolidation level. That determines whether the obligation applies, and from which financial year. Companies already reporting should note that the exemption for financial years 2025 and 2026 does not yet exist in Dutch law.
- Choose the report form. The sustainability statement can be set up as a standalone report or integrated into the financial annual report. That choice drives the entire process — from data collection to publication — and is better made early than late.
- Map the data sources. ESRS data points come from more systems than the financial administration alone: HR, energy, procurement, operations. Map now where the data lives and who owns it.
- Design tagging and assurance in. A reporting process that accounts for XBRL tagging and for the verifiability of every statement from the start avoids having to retrofit both onto a PDF afterwards.
How Taxxor does this
Taxxor Disclosure Manager treats the sustainability statement like financial reporting: structured data from source systems, one platform for the financial annual report and the sustainability statement, ESRS XBRL tagging inside the platform itself — including text tagging of policy and disclosure narratives — and full data lineage for assurance. Teams already reporting with Taxxor DM add sustainability on the same platform.
More on the approach, from scope to tagged report: CSRD reporting with Taxxor.