European UnionDelayed
Corporate Sustainability Due Diligence Directive
Omnibus I in force since March 2026; transposition due July 2028 and application from July 2029.
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The EU sustainability reporting regime requiring double materiality disclosure, now substantially narrowed by the 2025 simplification omnibus.
Omnibus narrowed scope to 1,000 employees from FY2027; first wave reporting continues with opt-outs.
In plain language
The CSRD requires in-scope companies to report against the European Sustainability Reporting Standards on a double materiality basis, covering both the company's impacts on people and planet and the sustainability risks it faces. The first wave of reports was published in 2025.
The 2025 omnibus significantly raised the employee threshold, removed many mid-sized companies from scope, and delayed later reporting waves by two years while the standards themselves are simplified. For suppliers, the value chain disclosures remain the important part: buyers request primary data from suppliers to populate their own reports, and that request cascade continues regardless of the scope changes.
Obligations
Companies must assess and disclose both impact materiality and financial materiality across environmental, social and governance topics.
Reporting extends beyond own operations to material impacts in the upstream and downstream value chain, subject to transitional relief.
Sustainability statements require limited assurance, with a pathway towards reasonable assurance over time.
Timeline
Directive entered into force across the European Union.
First wave of CSRD-aligned reports published by the largest listed companies.
Stop-the-clock directive postponed waves two and three by two years.
Political agreement raised the threshold to 1,000 employees and removed the listed SME wave.
Omnibus I published; member states transpose the CSRD provisions by 19 March 2027.
Revised scope applies for financial years starting on or after this date.
Changelog
Entry updated to reflect the revised thresholds and the delayed reporting calendar.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Sources
Same jurisdiction
Omnibus I in force since March 2026; transposition due July 2028 and application from July 2029.
Read →Second postponement published one week before application; large operators now start on 30 December 2026.
Read →Commission published its enforcement guidelines on 30 June 2026, alongside a provisional list of national competent authorities.
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