CSRD Omnibus Scope Self-Test
Answer a few quick questions to see whether your undertaking is still in mandatory scope under the revised CSRD thresholds. Most assessments take under a minute.
Use this free CSRD scope test to check whether your undertaking is still subject to mandatory sustainability reporting after the Omnibus I changes that entered into force on 18 March 2026 — covering the 1,000 employees and €450 million net turnover test for EU undertakings, the listed SME exclusion, and the Article 40a rules for non-EU groups with a qualifying €200 million EU subsidiary or branch.
Regulatory basis last reviewed against Directive (EU) 2026/470 — 27 August 2026. We review this test when relevant EU legislation, guidance or implementation changes.
Ready when you are
Before you start
This test applies the CSRD scope rules amended by Omnibus I, in force since 18 March 2026. It is a self-assessment tool, not legal advice — the final question in most results points you to what to verify with counsel or your assurance provider. Your answers are never transmitted or stored — they exist only in this browser tab.
1. How is your undertaking structured?
Pick the description closest to your situation.
2. Is your company’s equity listed on an EU regulated market, and would it qualify as a small or medium-sized enterprise in its own right — that is, NOT a large undertaking?
This matters because the Omnibus removed listed SMEs from mandatory CSRD scope entirely, regardless of the thresholds below.
3. Average number of employees during the financial year
Use the consolidated group figure if you are testing as a parent undertaking.
Whole number. Commas are fine.
Enter a number of zero or more.
4. Annual net turnover, in € million
Consolidated group turnover if you are testing as a parent undertaking.
Enter the figure in millions — for €520,000,000 enter 520.
Enter a number of zero or more.
2. Does your own EU subsidiary, as an undertaking in its own right, exceed both 1,000 employees and €450 million net turnover?
This is separate from the Article 40a test for the wider non-EU group, and it only applies to a subsidiary — a legally separate EU undertaking. An EU subsidiary that independently meets both thresholds is in scope under the ordinary large-undertaking rule (Article 19a of the Accounting Directive) — or Article 29a, on a consolidated basis, if that subsidiary is itself the parent of its own sub-group — regardless of the wider non-EU group’s position. A branch is not tested this way, since a branch has no separate legal personality of its own; branches are assessed only under the Article 40a route further on.
3. In each of the last two consecutive financial years, did your group generate more than €450 million in net turnover within the EU?
This is the group’s EU-generated turnover, not its worldwide turnover.
4. Does the third-country undertaking have an EU subsidiary with net turnover exceeding €200 million in the preceding financial year?
Turnover alone — there is no employee-count or large-undertaking-status condition on this route. That condition applied under the original Article 40a text and was removed by the 2026 revision.
5. Since there is no qualifying subsidiary, does the third-country undertaking have an EU branch with net turnover exceeding €200 million in the preceding financial year?
The branch route only applies because no qualifying subsidiary exists — it is not an alternative you could choose instead of one. Same €200 million threshold, same absence of an employee condition.
One more question — it changes what you should do next, not your scope result.
Was your undertaking already reporting, or preparing to report, sustainability information under the original CSRD before the Omnibus changes — for example for financial year 2024 or 2025?
Sources and basis for this test
- Directive (EU) 2026/470 (Omnibus I), in force 18 March 2026 — the 1,000-employee / €450m thresholds for EU large undertakings, and the listed-SME exclusion
- Article 40a of the Accounting Directive, as amended by Directive (EU) 2026/470, Article 2(13) — read directly from the amending text: EU turnover above €450m for the parent in each of the last two consecutive years; an EU subsidiary above €200m (turnover alone, no employee condition); or, only where no such subsidiary exists, an EU branch above the same €200m
- Council of the EU, press release, 24 February 2026 — third-country group thresholds
- EFRAG, ESRS for Certain Non-EU Undertakings in Accordance with Article 40a project page, 2026 — consistent with the €200m subsidiary/branch figures confirmed above
- Bird & Bird, “Omnibus I Directive entered into force” client briefing, July 2026 — consistent with the same thresholds and their distinction from the EU large-undertaking route
- Latham & Watkins, summary of European Commission FAQs on the CSRD — confirms an EU subsidiary “within the scope of the CSRD in its own right” is tested independently of the Article 40a group-level route, which is why this tool checks that first
- European Commission, FAQ Notice on the CSRD, Official Journal C/2024/6792, 13 November 2024 — read directly. Describes the pre-revision Article 40a: the subsidiary route required Article 19a/29a large-undertaking status, and the branch route applied only in the absence of such a subsidiary. Superseded on the status point, as confirmed directly below.
- Directive (EU) 2026/470, Article 2, point (13), Official Journal L series, 26 February 2026 — the operative amending text, read directly. Replaces the subsidiary condition with a pure turnover test above €200 million; confirms the branch route applies “only… where the third-country undertaking does not have a subsidiary undertaking” meeting that test; confirms the €450 million EU group turnover gate “for each of the last two consecutive financial years.”
- European Commission press release, 3 July 2026 — reporting population estimate (~50,000 to ~5,000 undertakings)
Resolved 27 August 2026: an earlier version of this tool flagged the subsidiary/branch mechanics as unconfirmed, based on a 2024 FAQ Notice that predates the 2026 revision. We subsequently read the amending Directive’s own text (Directive (EU) 2026/470, Article 2(13)), which settles both open points: the EU subsidiary route is a turnover test alone, with the large-undertaking-status condition removed; the EU branch route remains subordinate, applying only where no qualifying subsidiary exists. Both are reflected in the questions above.
This tool reflects our reading of the rules as at 27 August 2026 and does not constitute legal advice. Confirm any scope conclusion with your assurance provider or counsel before relying on it for a filing decision. Full guide: aigreentools.com/what-is-esrs/#scope
Frequently asked questions about CSRD scope
Who is in mandatory CSRD scope after the 2026 Omnibus changes?
EU undertakings — or EU parents of a group — that exceed both 1,000 employees and €450 million net turnover on their balance sheet date. Both conditions are required together; exceeding only one does not bring an undertaking into mandatory scope. The same 1,000-employee and €450 million test also applies to an EU subsidiary of a non-EU group, tested on its own, independently of the group’s wider position.
Are listed SMEs still required to report under CSRD?
No. Small and medium-sized undertakings whose securities are listed on an EU regulated market were removed from mandatory CSRD scope by the Omnibus I changes, regardless of the employee and turnover thresholds that apply to large undertakings. They may still report voluntarily.
What is Article 40a and who does it apply to?
Article 40a of the Accounting Directive is the CSRD scope route for non-EU (“third-country”) groups. It applies where the group generates more than €450 million of net turnover in the EU in each of the last two consecutive financial years, and has a qualifying EU subsidiary or branch. It is separate from, and applies in addition to, the ordinary large-undertaking test for EU-incorporated entities.
What is the EU subsidiary threshold under Article 40a?
More than €200 million net turnover in the preceding financial year — a turnover test alone, with no employee-count or large-undertaking-status condition. That status condition existed under the original CSRD text and was removed by the 2026 Omnibus revision (Directive (EU) 2026/470, Article 2(13)).
Does the EU branch route apply if there’s a qualifying subsidiary?
No. The EU branch route under Article 40a is explicitly subordinate: it only applies where the third-country undertaking does not have a qualifying EU subsidiary. Where a qualifying subsidiary above €200 million exists, the branch test is not relevant. Where none exists, the branch itself must independently exceed the same €200 million threshold.
When did the new CSRD scope thresholds take effect?
The Omnibus I Directive, which raised the thresholds and removed listed SMEs from mandatory scope, entered into force on 18 March 2026. The first financial year under the revised thresholds is the one beginning on or after 1 January 2027, with statements published in 2028.
