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EU · Reporting · Directive (EU) 2022/2464

CSRD and Scope 3: the right data, not more.

After the Omnibus I Directive (EU) 2026/470, CSRD reporting applies only to companies with more than 1,000 employees and over €450 million net turnover, and to large non-EU groups with substantial EU business. Suppliers with up to 1,000 employees are protected: customers cannot require more sustainability data from them than the EU voluntary standard covers.

Plan my supplier data See the key dates
1,000+
employees for CSRD scope
€450m
net turnover threshold
1,000
employee cap on supplier requests
Status · checked 28 Sep 2026 Narrowed from 18 Mar 2026
  1. Stop-the-clock directive
  2. Omnibus I enters into force
  3. Revised ESRS and voluntary standard adopted
  4. 28 Sep 2026
All dates and references ↓
The short answer

What you need to know.

Checked against official sources on 28 September 2026.

  1. 01

    The Omnibus I Directive (EU) 2026/470 of 24 February 2026 amends the CSRD. It was published on 26 February and entered into force on 18 March 2026; Member States transpose it by 19 March 2027.

  2. 02

    CSRD reporting now applies to undertakings and groups with more than 1,000 employees and over €450 million net turnover. Non-EU groups are in scope above €450 million EU turnover (two consecutive years) with an EU subsidiary or branch above €200 million.

  3. 03

    Suppliers with up to 1,000 employees are “protected undertakings”. Reporting customers may not require information beyond the voluntary standard, and protected suppliers may refuse such requests. A self-declaration of size is enough.

  4. 04

    The earlier stop-the-clock Directive (EU) 2025/794 postponed by two years the first reports of companies due to start with 2025 or 2026. In-scope large companies apply the rules for financial years from 1 January 2027.

  5. 05

    On 3 July 2026 the Commission adopted revised ESRS, with over 60% fewer mandatory datapoints, and the voluntary standard. EFRAG reports they apply to financial years from 1 January 2027 once the delegated act enters into force.

Who it applies to

Big reporters ask. Smaller suppliers answer.

The CSRD itself now reaches only the largest companies. Its data needs still travel down the supply chain as Scope 3 requests.

In scope

EU companies and groups

More than 1,000 employees on average and net turnover above €450 million, on an individual or consolidated basis.

In scope

Non-EU groups

EU net turnover above €450 million in each of the last two years, with an EU subsidiary or branch above €200 million.

Protected

Suppliers up to 1,000 employees

Asked for value chain data, but only up to the voluntary standard. Most small and mid-sized factories in India, China and Vietnam are here.

Now outside

Former first-wave reporters

Companies below the new thresholds leave the scope from financial year 2027. Member States may exempt them for 2025 and 2026.

Key dates

Every date, with its source.

Only dates set in law or official publications. Anything still proposed is marked as proposed.

  1. Stop-the-clock directive

    Postpones by two years the reporting start for companies due to report first for financial years 2025 or 2026.

    Directive (EU) 2025/794Adopted

  2. Omnibus I adopted

    New scope thresholds, value chain cap, voluntary standard, sector-specific standards dropped, reasonable assurance removed. Published in the Official Journal on 26 February 2026.

    Directive (EU) 2026/470Adopted

  3. Omnibus I enters into force

    Directive (EU) 2026/470, Art. 6In force

  4. Revised ESRS and voluntary standard adopted

    Mandatory datapoints cut by over 60% and total datapoints by more than 70%. They apply once the two-month scrutiny period (extendable by two months) ends.

    Commission delegated actAdopted
  5. Today · 28 September 2026
The value chain cap

How the 1,000-employee cap works.

The Omnibus protects smaller companies in the value chain from disproportionate data requests. Here is the logic in four steps.

  1. 01Your customer asks for data

    A company reporting under the CSRD needs value chain information, often for Scope 3 emissions.

  2. 02You declare your size

    Up to 1,000 employees on average in the previous year makes you a protected undertaking. Your self-declaration is enough.

  3. 03The voluntary standard sets the limit

    Your customer may not require information beyond what the voluntary standard covers.

  4. 04You choose to share more

    Beyond that limit, you have a statutory right to refuse. Many suppliers share more to win business.

What you need from suppliers

Activity data that answers Scope 3 questions.

What your EU customers need for their purchased-goods emissions, and what you should ask your own suppliers for in turn.

  • Energy use by sourceGrid electricity, captive power, diesel, gas and coal, per month, with meter or invoice evidence.
  • Production outputUnits or tonnes produced in the same period, to allocate energy per product.
  • Materials per productMaterial types and weights in the bill of materials, including recycled content where known.
  • Inbound and outbound transportDistances, modes and weights for the main legs.
  • Waste and waterQuantities by type and how they are treated, where your customer’s material topics call for it.
  • Headcount self-declarationAverage employees in the previous financial year, so your customer can confirm protected status.
How SourceSquid helps

From your product list to an audit-ready file.

Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs.

  1. 01

    Request design

    Supplier questionnaires trimmed to what your reporting needs and the voluntary standard allows.

    You receiveSupplier data request
  2. 02

    On-site collection

    Energy bills, meter readings and production logs gathered at the factory in the local language.

    You receiveActivity data per supplier
  3. 03

    Allocation and calculation

    Energy and materials allocated to your products and converted with documented emission factors.

    You receiveProduct-level emissions
  4. 04

    Data quality flags

    Measured, estimated and default values clearly marked, with a plan to improve the weakest.

    You receiveData quality log
  5. 05

    Disclosure-ready output

    Supplier data delivered in a format your sustainability team and assurance provider can use.

    You receiveDisclosure-ready dataset
  6. 06

    Yearly refresh

    The same suppliers, the same method, updated each year so trends are comparable.

    You receiveAnnual update
Sources

Official texts behind this page

Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser.

  1. Directive (EU) 2026/470 (Omnibus I) amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760Scope thresholds; protected undertakings; Art. 29ca voluntary standards; Art. 5 transposition
  2. Directive (EU) 2025/794 (stop-the-clock)
  3. Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive)
  4. European Commission: revised sustainability reporting standards adopted (3 July 2026)
  5. EFRAG: Commission publishes delegated act on revised ESRS and voluntary standardApplication from financial years beginning on or after 1 January 2027
Related compliance guides

Rules that often travel together.

EU · carbonCBAMCarbon Border Adjustment Mechanism: embedded emissions and certificates for steel, aluminium and more.EU · deforestationEUDRDeforestation Regulation: due diligence statements and plot geolocation for seven commodities.Management systemsISO 9001 and 14001Quality and environmental certification for suppliers, including the 2026 editions.
CSRD and Scope 3 questions

Straight answers.

Dates checked against official sources. We update this page when the rules move.

[email protected]

Does the CSRD still apply to my company after the Omnibus?

Only if you are large. Directive (EU) 2026/470 limits CSRD sustainability reporting to EU undertakings and groups with more than 1,000 employees on average and a net turnover above €450 million. Non-EU groups are in scope when their EU net turnover exceeds €450 million in each of the last two consecutive financial years and they have an EU subsidiary or branch with net turnover above €200 million.

Can my EU customer demand Scope 3 data from my factory?

If your company has up to 1,000 employees on average, you are a “protected undertaking” under the Omnibus. Customers reporting under the CSRD cannot require more information from you than the EU voluntary sustainability reporting standard covers, and you have a statutory right to refuse requests beyond it. You can still share more if you choose, and customers may rely on your self-declaration of size.

When do companies in the new CSRD scope report?

The stop-the-clock Directive (EU) 2025/794 postponed by two years the first reports of companies that were due to start with financial year 2025 or 2026. Under the amended rules, large undertakings above the new thresholds apply the requirements for financial years starting on or after 1 January 2027. Member States transpose the Omnibus changes by 19 March 2027.

What is the voluntary sustainability reporting standard?

A standard the Commission adopted on 3 July 2026 for undertakings with up to 1,000 employees that are not required to report. It lets suppliers answer customers’ sustainability questions once, in a common format, and it sets the limit of the value chain cap: in-scope companies cannot require more than it covers from protected suppliers.

What data should a supplier prepare for customers’ Scope 3 reporting?

The most useful data is activity data: electricity and fuel use by source, production output to allocate it per unit, material types and weights per product, inbound transport, and waste. With these, a customer can calculate the emissions of the goods it buys from you (Scope 3, purchased goods and services) instead of relying on spend-based estimates.

Start here

Supplier emissions data, collected once, used everywhere.

Tell us which suppliers your customers or your own report depend on. We return a data plan sized to what the rules actually require.

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