Guide and workbook · 2026

CSRD after the Omnibus:
the community data you still need

From financial year 2027, EU companies are covered by the CSRD only if they exceed both €450 million turnover and 1,000 employees. The revised ESRS no longer name social investment programmes, yet community data still feeds S3-3, the ESRS 2 general rules and G1-5 when material. Collect it every quarter and it is ready whether or not your company reports under the CSRD.

Published October 2026 · Law as of 21 October 2026, not legal advice · 25 verified sources · ~15-minute read
CSRD scope from FY2027
€450m
net turnover and over 1,000 employees
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Both tests must be met
Revised ESRS mandatory from
FY2027
enter into force on 10 November 2026
icon check
Commission: over 60% fewer mandatory datapoints
Value chain cap
1,000
employees or fewer may decline extra requests
icon check
B2 and C2 stay voluntary
Data from
Official Journal of the EU
|
European Commission
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EFRAG
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EU Publications Office
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Bundestag
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Tweede Kamer
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Sénat
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Moniteur belge | Finlex | Riksdagen | Folketinget
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FoundationMark
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PKF O'Connor Davies
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Congress.gov
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Optimy research
Decorative shape for background usage - logo pattern
TL;DR

Key findings

1
Only the largest companies report from FY2027

From FY2027, the CSRD covers EU companies only above both €450 million net turnover and 1,000 employees.1 Wave one, reporting since FY2024, stays in from 2027 only above both, and countries may exempt the rest for 2025 and 2026.1 Others above both start with 2027.1,2

2
From financial year 2027, the revised ESRS ask for less data

The revised standards enter into force on 10 November 2026 and apply to financial years starting on or after 1 January 2027.5 Current ESRS reporters may apply them a year early, for financial year 2026.5 The Commission says they cut mandatory datapoints by over 60%.6

3
Social investment programmes are no longer named

The 2023 ESRS S3 named social investment programmes, and the revised S3, with four disclosure requirements, drops that wording.9,5 From FY2027, or FY2026 for early adopters, they are reported mainly as S3-3 key actions when communities are material, or as entity-specific or labelled supplementary information.5

4
Significant programme spend must trace to the accounts

Under ESRS 2 GDR-A paragraph 46(b), significant financial resources behind a key action are disclosed with the financial-statement line items or notes that include them.5 Where communities are material and spend is significant, it must be traceable to the accounts.

5
Giving can count as a political contribution

Under ESRS G1-5, donations, sponsorships and fundraising tickets count as political contributions when they reach parties, elected representatives or candidates.5 When political influence is material, the total is disclosed by country where relevant and by type of recipient.5

6
Five of the seven countries covered had no Omnibus law yet

Member States must transpose the Omnibus by 19 March 2027.1 On 21 October 2026, Finland had transposed the new scope and Belgium had done so in part.22,21 Germany and the Netherlands had not yet transposed even the original CSRD.14,18

7
Smaller partners can decline extra requests

From financial year 2027, value-chain companies with 1,000 employees or fewer may refuse CSRD requests beyond the voluntary standard.1,10 B2 and C2, which cover practices, policies and future initiatives, sit outside the cap list, so a CSRD customer cannot require them for CSRD purposes.10

8
First-time reporters may omit S3 for two years

Companies first reporting from financial year 2027 may omit all S3 disclosures for their first two years.5 If communities are material, they must still summarise policies, actions, targets and metrics under ESRS 2 BP-2, so programme data is needed from the first report.5

Chapter 1

From financial year 2027, EU companies report only above both €450 million and 1,000 employees

From financial year 2027, the Corporate Sustainability Reporting Directive (CSRD) covers a smaller group of companies, and they report against a revised set of European Sustainability Reporting Standards (ESRS).1,5 Two directives produced this change. The stop-the-clock Directive of April 2025 delayed the second wave of reporters by two years, and the Omnibus I Directive of February 2026 cut the scope itself.2,1

Omnibus I, formally Directive (EU) 2026/470, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026.1 Its new scope governs financial years starting on or after 1 January 2027, and Member States must write it into national law by 19 March 2027.1

€450m

net turnover a company must exceed from financial year 2027

1,000

average employees it must exceed as well

2 years

delay for wave two under the stop-the-clock rule

2028

first financial year for non-EU groups' EU reports, if EU turnover exceeds €450m in each of the last two years and the subsidiary or branch exceeds €200m

The main EU texts are published, and the next deadlines fall in 2027

‍

Date What happens Status
16 April 2025 Stop-the-clock Directive (EU) 2025/794 is published; it moves wave two to financial years starting on or after 1 January 2027.2 In force since 17 April 2025
10 November 2025 The wave-one quick fix, Delegated Regulation (EU) 2025/1416, is published.4 Wave one may omit all of ESRS S3 for its first three years of reporting, which run to financial year 2026.4 Applies from FY2025
3 December 2025 EFRAG, the Commission's technical adviser, delivers draft simplified ESRS that cut mandatory datapoints by 61%.7 Advice only, not law
31 December 2025 Deadline for Member States to transpose the stop-the-clock postponement.2 Deadline passed
26 February 2026 Omnibus I, Directive (EU) 2026/470, is published in the Official Journal.1 In force since 18 March 2026
3 July 2026 The Commission adopts the revised ESRS (Delegated Regulation (EU) 2026/1563) and the voluntary standard (Delegated Regulation (EU) 2026/1560).5,10 Adopted
21 September 2026 Both delegated regulations are published in the Official Journal, as EFRAG confirmed the next day.5,8 Published
24 September 2026 The voluntary standard enters into force and replaces the 2025 VSME Recommendation, which no longer has legal effect.10 In force
10 November 2026 The revised ESRS enter into force.5 Published, not yet in force
1 January 2027 Financial years starting on or after this date fall under the new scope and the revised ESRS; the value chain cap applies from then too.1,5,10 Scope applies via national law
19 March 2027 Deadline for Member States to write the Omnibus changes into national law.1 Deadline
1 July 2027 Deadline for the Commission's limited assurance standards; the planned move to reasonable assurance is dropped.1 Set by Omnibus I
1 January 2028 Non-EU groups start reporting through an EU subsidiary or branch, for financial years starting on or after this date.3,1 It applies only if EU turnover exceeds €450 million in each of the last two years and the subsidiary or branch exceeds €200 million.1 Date unchanged

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Who drops out, and who stays in

The new test for EU companies has two parts, and a company must pass both. It must exceed €450 million net turnover and an average of 1,000 employees in the financial year, and groups apply the same test on a consolidated basis.1 Companies above both thresholds that were not in wave one, the old wave two, first report for financial year 2027, so calendar-year companies publish their first statements in 2028.1

Which financial years your company reports for under EU law

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Your company Financial year 2025 Financial year 2026 From financial year 2027
Wave one (reporting since financial year 2024), above both thresholds1 Reports Reports Reports
Wave one, below one or both thresholds1 Reports, unless your country uses the exemption Reports, unless your country uses the exemption Out of scope
Not in wave one, above both thresholds2,1 No, start delayed No, start delayed Reports, first statement in 2028 for a calendar-year company
Not in wave one, not above both thresholds, including listed SMEs1 No No No
Non-EU group reporting through an EU subsidiary or branch (a subsidiary that itself meets the EU tests follows the rows above)3,1 No No From financial year 2028, if EU turnover exceeds €450m in each of the last two years and the subsidiary or branch exceeds €200m

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Both thresholds means more than €450 million net turnover and an average of more than 1,000 employees, on a consolidated basis for groups. The 2025 and 2026 exemption is a Member State option, and Chapter 4 shows which of the seven countries had used it by 21 October 2026. These are the EU rules: they reach your company through national law, so confirm your own position with your auditor.1

  • Wave one drops out unless it exceeds both thresholds. Companies reporting since financial year 2024 that do not exceed both thresholds leave the CSRD for financial years starting on or after 1 January 2027.1 Each Member State may also exempt them for 2025 and 2026, so those two years depend on your country.1
  • Listed SMEs leave mandatory reporting. Listed small and medium-sized companies are removed from mandatory CSRD reporting.1 Chapter 5 covers what customers can still ask of companies outside the CSRD.
  • Non-EU groups report later, and only above a high bar. From financial year 2028, a non-EU group reports through an EU subsidiary or branch only above €450 million in EU net turnover.1,3 That level must be exceeded in each of the last two years, and the reporting subsidiary or branch must itself exceed €200 million net turnover in the preceding year.1
  • Assurance stays limited. The Omnibus drops the planned move to reasonable assurance, so sustainability statements remain under limited assurance.1

For financial year 2026, current reporters choose between three ESRS routes

The revised ESRS were adopted on 3 July 2026 as Delegated Regulation (EU) 2026/1563, published on 21 September 2026, and enter into force on 10 November 2026.5 They are mandatory for financial years starting on or after 1 January 2027. For financial year 2026, Article 2(1) of the same regulation lets companies already under the ESRS choose between three routes once it is in force:5

  • The 2023 ESRS, as amended by the 2025 quick fix.4,5
  • The revised 2026 ESRS, applied a year early.5
  • The 2023 ESRS with eight listed reliefs taken from the revised set.5

Whichever route you take, the statement must say which version was applied.5 The revised set is also leaner: the Commission says it cuts mandatory datapoints by over 60% and total datapoints by over 70%.6

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The Commission says the revised ESRS cut mandatory datapoints by over 60%

Reduction in ESRS datapoints, by measure and source

Mandatory datapoints, adopted ESRS
over 60%
Total datapoints, adopted ESRS
over 70%
Mandatory datapoints, EFRAG advice
61%
Sources: European Commission, 3 July 2026, for the adopted standards; EFRAG, 3 December 2025, for its technical advice. Bars for 'over' figures show the stated minimum.6,7

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EFRAG, the Commission's technical adviser on the standards, had proposed a 61% cut in mandatory datapoints in its advice of 3 December 2025.7 The Commission did not adopt that advice unchanged: it modified it on materiality, fair presentation, aggregation, omission of information and anticipated financial effects, among other points.5 No sector standards will add datapoints later either, because the Commission's power to adopt them has been deleted.1

With the scope and the standards settled, the next question is which community data the revised ESRS still use.

Takeaway: run the two-part scope test for your company and your group now, and check whether your country uses the 2025 and 2026 exemption. If you report for financial year 2026, decide which ESRS version you will apply and record it, because the statement must say so.

Chapter 2

Which community data still counts: S3-3, the ESRS 2 rules and G1-5

Outside the political-contribution rules of G1-5, the revised ESRS never name community investment, volunteering, donations or sponsorship. Your programmes still count, because ESRS S3 on affected communities asks for the key actions and resources a company uses to manage its material impacts on communities.5 When S3 is material, programmes that serve as such key actions are reported under S3-3, even though the standard does not name them.5

Everything in this chapter depends on materiality. In the revised ESRS, a 'shall disclose' requirement applies only if the information is material, and S3 is reported only when affected communities are material.5 The tables cite the ESRS 2 rules for policies, actions, targets and metrics as GDR-P, GDR-A, GDR-T and GDR-M. Each 'required' status assumes the topic is material, and the S3 rows apply in full only after the phase-in.5

4

disclosure requirements in the revised S3, S3-1 to S3-4

3 years

wave one may omit all of S3: its first three reporting years, to financial year 2026

2 years

S3 phase-in for companies first reporting from 2027

0

programme metrics prescribed by S3 itself

S3 rows: policies, engagement, actions, targets and metrics

‍

ESRS reference What it asks What the programme supplies Status
S3-1 para 8, with ESRS 2 GDR-P para 42 Policies on affected communities5 Your community investment, giving, volunteering and sponsorship policy: objectives, entities and countries covered, target communities, external standards and how communities shaped it Required if S3 material
S3-2 para 11 Engagement with affected communities and how their views inform decisions5 Needs assessments, consultations with beneficiaries and local partners, how often they happen, how input changed decisions, and how vulnerable or marginalised groups are heard Required if S3 material
S3-2 para 13 Channels to raise concerns, and how their effectiveness is assessed5 Any feedback or complaint channel for grantees, beneficiaries and local communities, whether it is a formal grievance mechanism, and how you check it works Required if S3 material
S3-3 para 15, with GDR-A para 45(a) Key actions taken and planned, with their timeframe5 A register of the programmes you treat as key actions: what was done this year, what is planned and over what period Required if S3 material
GDR-A para 45(b) Scope of each key action5 Legal entity, country, site and the community groups targeted, per programme Required if S3 material
GDR-A para 45(c) Expected outcomes and the policy objective each action serves5 Intended outcomes per programme, such as people reached or services delivered, and the policy objective behind each Required if S3 material
S3-4 para 18, with GDR-T para 51 Targets related to affected communities5 Any measurable, time-bound community target: value and unit, scope, baseline and base year, target year, milestones and method Required if a target exists
GDR-T para 52 How effectiveness is tracked where no outcome targets exist5 The monitoring and evaluation process you use to judge whether programmes work Required if no target
GDR-M paras 48 and 49, with AR 42 Definition, unit, method and sources for each metric you report5 For hours volunteered, participation, beneficiaries or amounts donated: definition, unit, calculation method, data sources, estimates and year-on-year change Required if reported
ESRS 2 BP-2 paras 8 and 9 A short summary of a material S3 topic while the S3 phase-in is used5 A brief narrative of the community policy, actions and results, any targets and progress, and relevant metrics Required if S3 material
ESRS 1 paras 11 and 12 Entity-specific disclosures where ESRS do not cover a material topic in enough detail5 Programme data built for comparison over time and with peers in the same sector Required if material
ESRS 1 paras 107 to 109 Supplementary information that is not material5 Community investment totals by type, prepared under another framework, labelled as such and referenced to that framework Optional

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Phase-in: wave one may omit all of S3 before financial year 2027, and companies first reporting from 2027 may omit it for their first two years. Full S3 therefore applies from financial year 2027 for wave one, and from the third reporting year for companies first reporting from 2027. Until then, a material S3 topic still needs the ESRS 2 BP-2 summary.5

Spend must be traceable to the accounts, and time counts too

Under ESRS 2 GDR-A paragraph 46(b), where significant financial resources go to a key action, the company discloses the amount for the period. It must also indicate the line items or notes in the financial statements where that amount sits.5 Programme spend must therefore be traceable to the accounts, which makes it a finance task as much as a CSR one.

Time counts too. The ESRS define an action as a decision to commit financial, human or technological resources, so staff time behind a programme is a resource.5 ESRS 2 GDR-A AR 40 allows significant non-financial resources, such as full-time equivalent (FTE) staff, to be shown in non-monetary units. Employee volunteering time committed to a key action can be shown this way, although ESRS does not mention volunteering.5

‍

ESRS reference What it asks What the programme supplies Status
GDR-A para 46(a) Type of significant financial resources and any preconditions5 Operating or capital expenditure, cash or in-kind, and whether delivery depends on co-funding or public grants Required if significant
GDR-A para 46(b) Amount allocated in the period, with financial-statement line items or notes5 Totals for cash donations, grants, sponsorship fees, valued in-kind gifts and running costs, each mapped to a ledger account and note Required if significant
GDR-A para 46(c) Indicative range of future financial resources5 Approved or announced budgets for coming years, as a range, with planned funding sources Required if significant
GDR-A AR 39 A table split by capital and operating expenditure, current and planned5 The same spend figures, laid out by CapEx and OpEx and by time horizon Optional
GDR-A AR 40 Significant non-financial resources in non-monetary units5 Volunteering and pro bono hours per programme and country, converted to FTE, with the conversion basis Optional
GDR-A AR 36 Whether a key action is collaborative5 A flag for partnerships with NGOs, other companies, public bodies or communities Optional

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Required if significant applies only when the topic is material and the resources are significant. CapEx means capital expenditure and OpEx operating expenditure. The CapEx or OpEx type itself is required if significant under paragraph 46(a); only the AR 39 table layout is optional.5

Social investment wording is gone, so map programmes as key actions

The 2023 ESRS S3 explicitly covered social investment and development programmes. Its application requirements AR 34 and AR 35 invited voluntary detail on how communities helped design them, their outcomes and the communities covered.9 The revised 2026 S3 drops these requirements. From financial year 2027, or 2026 for early adopters, such programmes are reported mainly as key actions under S3-3 and ESRS 2 GDR-A.5

That route applies when affected communities are material. If they are material but ESRS does not cover your programmes in enough detail, ESRS 1 asks for entity-specific disclosures built for comparison over time and with sector peers.5 If affected communities are not material, the figures can appear as clearly labelled supplementary information, covered at the end of this chapter.

Volunteering counts under S1 only if you make it an action

ESRS S1, the standard on a company's own workforce, does not name volunteering either. Volunteering belongs in S1 only if you treat it as an action on a material sub-topic, such as work-life balance or training and skills development.5 That is a company judgement, and once made, the volunteering policy and any participation target fall under S1-1 and S1-4 too.5

Two S1 datapoints touch programme data even when volunteering is not an action. Using S1-5 headcount as the denominator for a participation rate keeps your programme figures consistent with the sustainability statement.5 Under S1-12 AR 23, training hours cover only training offered to and completed by employees, so a skills-based volunteering scheme counts only if you classify it as training.5

Screen every donation and sponsorship for political recipients

Donations and sponsorships appear by name in ESRS G1, the standard on business conduct, in its rules on political contributions. Under G1-5, donations, sponsorships, ticket purchases for fundraising events and in-kind support count as political contributions when they go to political parties, elected representatives or candidates.5

Indirect contributions, also covered by G1-5, are those made through an intermediary such as a lobbyist or charity.5 They also include support to a think tank or trade association linked to or supporting particular political parties or causes.5 For a charity, the test is whether contributions pass through it to political recipients.

When political influence is material, G1-5 asks for the total monetary value of financial and in-kind contributions, direct and indirect, by country where relevant and by type of recipient.5 The practical answer is a screening field on every donation and sponsorship record, filled in when the request is approved rather than at year-end.

S1 and G1 rows at a glance

‍

ESRS reference What it asks What the programme supplies Status
S1-1, S1-3 and S1-4, with ESRS 2 GDR-P, GDR-A and GDR-T Own-workforce policies, actions and targets5 Volunteering leave policy and participation targets, only if volunteering is an action on a material S1 sub-topic Required if S1 material
S1-5 para 20 Employee headcount, in total and by gender, and by country for the ten largest countries with 50 or more employees5 Nothing directly: it is the denominator for volunteering participation rates Required if S1 material
S1-12 para 35(b), with AR 23 Average training hours per employee5 Training given through a skills-based volunteering scheme, only if the company classifies it as training Required if S1 material, phased in
G1-5 para 14 Total political contributions, financial and in-kind, direct and indirect, by country and recipient type5 Amount, country and recipient type for any gift that reached a party, elected representative or candidate Required if G1 material
G1-5 AR 7 and AR 8 What counts as a direct or indirect political contribution5 A screening field on every donation and sponsorship record, and a check on each charity, think tank or association Required if G1 material
G1-1 para 7(a) and (c) Anti-corruption policy and the roles most at risk5 Where the policy covers giving: approval thresholds, prohibited recipients, conflict checks, and whether approvers are at-risk roles Required if G1 material
G1-2 para 9(b) Procedures against corruption, including training for at-risk roles5 Due diligence on donation and sponsorship recipients, and anti-corruption training records for programme approvers Required if G1 material

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S1-12 is phased in: wave one may omit it before financial year 2027, and other companies may omit it in their first year.5

What you can still publish if communities are not material

The revised ESRS forbid non-material information prescribed by a datapoint, unless it is clearly labelled as supplementary.5 Community investment totals prepared under another framework, such as the GRI standards, can still appear in the statement on that basis. They must be identified as not resulting from the materiality assessment and refer to the framework used.5

Takeaway: map each programme to the row it feeds before you collect anything: S3-3 key actions, the GDR-A resource rules, G1-5 screening, or supplementary information. Then test materiality once a year, because it decides which rows you publish, while the data you collect stays the same.

Chapter 3

How to collect it every quarter, sheet by sheet

Year-end is the wrong moment to discover that a subsidiary cannot say what it spent or who it funded. The workbook below turns the rows of Chapter 2 into ten sheets, and you can fill it in on this page and download it as an Excel file. Local teams then send the same fields every quarter, and the central team consolidates them once.

In the downloaded file, each column header carries its ESRS reference and status below it and in a note on hover. Yellow reference cells mark required data, under the condition in the cell: materiality, significance or, in the Local entity request, your own collection rule. Cream cells mark optional, conditional, calculated or voluntary data. Drop-down lists fix the programme type, yes or no answers and the quarter, so figures add up without cleaning.

10

sheets, from Read me to Sources

8

programme types in the register's drop-down list

4

collection rounds a year, one per quarter

1

row per programme in the register

What each sheet collects

‍

Sheet What it collects ESRS link
Read me Who reports and when, which standard applies, and how to use the workbook Summary
Programme register One row per programme: type, legal entity, country, site, community groups, key-action flag, expected outcomes, policy objective, timeframe and partners S3-3, GDR-A 45
Resources Cash donations, grants, sponsorship fees, valued in-kind gifts and management costs per programme, country and period, with a calculated total and planned budgets. Each row also gives the financial statement line and CapEx or OpEx type, required if significant under GDR-A 46(a); the AR 39 table layout is optional. GDR-A 46, AR 39
Volunteering and pro bono Volunteering and pro bono hours per programme and country, converted to FTE, with participants, same-country headcount and a calculated participation rate GDR-A AR 40, S1-5
Metrics and targets One row per metric: definition and unit, method, baseline, target, value this period and linked policy, or how effectiveness is tracked without a target GDR-M, S3-4, GDR-T
Engagement and channels How communities are engaged and how often, the feedback channel, issues raised and how they were handled S3-2
Political screening Every donation and sponsorship recipient: amount, financial or in-kind, political flags, due diligence date and approver role G1-5, G1-1, G1-2
Local entity request The quarterly form each subsidiary or country team returns: programme, money by type, volunteering and pro bono hours, people or organisations reached and a political-recipient flag. It feeds the Programme register, Resources, Volunteering and pro bono, and Political screening. Feeds four sheets
VSME (B2, C2) Community practices, descriptions, future initiatives and targets for companies reporting under the voluntary standard VSME B2, C2
Sources The sources behind the guide and the workbook, with their links Sources

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Fill in the workbook here, then download it

Each tab below is one sheet. Add a row for each programme, recipient or metric, and the totals, FTE and participation rates update as you type. The download adds the Read me and Sources sheets and keeps the drop-down lists and formulas, so the file goes on working in Excel.

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Your entries are saved in this browser only and are never sent to Optimy.

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A quarterly routine in four steps

  • Step 1: register every programme once. Give each programme an ID in the Programme register and flag whether it is a key action on a material community impact. Every other sheet links back to that ID.
  • Step 2: send the Local entity request each quarter. Each subsidiary or country team reports its money, hours, people or organisations reached and any political recipient, with a named contact person.
  • Step 3: consolidate money and time. Copy the returns into Resources and into Volunteering and pro bono, tie each total to a financial statement line, and let the sheet convert hours to FTE and participation rates.
  • Step 4: screen, measure and check. Screen every new recipient in Political screening, update Metrics and targets and Engagement and channels, and note any gaps before the next quarter.

At year-end, the materiality assessment decides what you publish. Material topics go into the statement, and non-material community figures can appear only as labelled supplementary information, but the quarterly data is the same in both cases.5

Three design choices that save work at year-end

  • One programme ID across sheets. Money, time, metrics and screening all link to the register, so the scope of each key action (entity, country, community group) is recorded once.5
  • Headcount from the same source as S1-5. Participation rates use the headcount your sustainability statement reports, so the two figures reconcile.5
  • Screening at intake, not at year-end. A political flag on every recipient record answers G1-5 if political influence turns out to be material.5
Takeaway: send the Local entity request in the first week after each quarter closes, and consolidate it before the next one opens. Four small collections a year are easier to check than one large one, and they leave time to fix a missing ledger line.

Chapter 4

National law: where seven countries stand on 21 October 2026

The Omnibus changes reach companies only through national law, and the deadline for that is 19 March 2027.1 On 21 October 2026, the seven countries in this guide stood at very different stages. Two had not yet transposed even the original CSRD, Finland had already written the new scope into its Accounting Act, and Sweden had tabled no Omnibus bill.14,18,22,23

This guide covers Germany, the Netherlands, France, Belgium, Finland, Sweden and Denmark. It does not cover Norway or other countries, so check those with your adviser.

2

countries yet to transpose the original CSRD

1

country with the new scope in force: Finland

3

with a partial Omnibus law or a dedicated Omnibus bill: BE, FR, DK

2027

19 March: deadline for every Member State

Status by country

‍

Country Status as verified Latest step
Germany Original CSRD not transposed. Government bill (Drucksache 21/1857) at committee stage, already anticipating a 1,000-employee threshold, with no final vote.14 27 August 2026 (government answer)
Netherlands Original CSRD not transposed. Bill 36678 is held in committee until an announced amending memorandum arrives.18 12 February 2026
France Original CSRD transposed in 2023 and stop-the-clock in 2025. An Omnibus bill passed the Senate and is pending at the Assemblée nationale.11,12,13 Since 20 February 2026
Belgium CSRD transposed in 2024 and stop-the-clock in 2025. A law of 15 July 2026 partly transposes the Omnibus for wave one.19,20,21 31 July 2026
Finland Omnibus scope and the value chain cap written into the Accounting Act by Act 555/2026.22 30 June 2026
Sweden Stop-the-clock transposed by SFS 2025:1297. The old thresholds remain in law, and no Omnibus bill had been tabled.23 Checked 21 October 2026
Denmark Stop-the-clock transposed by Act 1636 of 16 December 2025. Omnibus bill L 7 tabled, with a first reading scheduled for 23 October 2026.24,25 7 October 2026

‍

National law also decides whether a wave-one company that does not exceed both new thresholds reports for 2025 and 2026. On 21 October 2026, the seven countries stood as follows:

  • Belgium: exempt from financial year 2026, though not for 2025.21
  • Finland: the amended Accounting Act applies to financial years starting on or after 1 July 2026 and may be applied to those that started on or after 1 January 2026.22 A company that has published a sustainability report for a financial year starting on or after 1 January 2024 no longer has to report unless it exceeds the new thresholds.22
  • France, Sweden and Denmark: no Omnibus law adopted yet, so no exemption in force.13,23,25
  • Germany and the Netherlands: the original CSRD is not yet transposed, so ask your auditor which rules apply.14,18

Germany and the Netherlands have not transposed the original CSRD

Germany's government bill, Bundestag Drucksache 21/1857, already anticipates raising the employee threshold to 1,000, but it remains at committee stage with no final vote recorded.14 The Legal Affairs Committee held a public hearing on it on 13 April 2026.15 On 27 August 2026, the government told the Bundestag that the further timetable was for the Bundestag to decide, and gave no completion date.16

The Commission's infringement procedure for late transposition, which a parliamentary question dates to September 2024, had not reached its next formal step, a reasoned opinion, by 2 June 2026.17 On 21 October 2026, Germany still had no national law transposing even the first version of the CSRD.14

The Netherlands is in the same position. Its implementation bill (Kamerstuk 36678), submitted on 13 January 2025, is pending in the Tweede Kamer, and no Dutch implementing measure appears in the EU data.18 On 12 February 2026, the finance committee decided to hold the bill until an announced amending memorandum arrives.18

France and Denmark have bills on the table, and Belgium has a partial law

France transposed the original CSRD by Ordonnance n° 2023-1142 of 6 December 2023, and the stop-the-clock postponement by Loi n° 2025-391 of 30 April 2025.11,12 The Omnibus is not yet French law. A new bill carrying the CSRD scope changes, with thresholds to be set by decree, passed the Senate on 18 February 2026. It has been pending before the Assemblée nationale since 20 February 2026, according to the Senate's legislative file.13

Denmark transposed the stop-the-clock postponement by Act 1636 of 16 December 2025.24 Its Omnibus bill, L 7, was tabled in the Folketing on 7 October 2026, with a proposed entry into force of 1 January 2027.25 The first reading is scheduled for 23 October 2026, and the bill would also repeal Denmark's national reporting duties on corporate social responsibility and data ethics.25

Belgium transposed the CSRD by a law of 2 December 2024, in force from 1 January 2025.19 A law of 12 December 2025 then replaced the 2025 start dates with 2027, and the 2026 start dates with 2028.20 Since a law of 15 July 2026, wave-one public-interest entities below €450 million turnover or 1,000 employees are exempt from financial year 2026.21

Finland has the new scope in force, while Sweden still uses the old test

Finland is furthest ahead. Act 555/2026, in force since 30 June 2026, limits the Accounting Act's sustainability reporting duty to companies and groups with over 1,000 employees on average and over €450 million turnover.22 Both tests must be met in the last closed and the preceding financial year. It applies to financial years starting on or after 1 July 2026, and may be applied from 1 January 2026.22

Finland also wrote two practical rules into law. A company that already reported for a financial year starting on or after 1 January 2024 no longer has to report unless it exceeds the new thresholds.22 And a reporting company may not contractually require a value-chain company with on average no more than 1,000 employees to provide more than the voluntary standard specifies.22

Sweden transposed the stop-the-clock postponement by SFS 2025:1297, so second-wave companies report for the first time for the financial year starting right after the end of 2026.23 The Omnibus thresholds, however, are not yet in its Annual Accounts Act. That act, amended up to SFS 2026:780, still uses the old test: more than one of three limits, in each of the last two financial years.23

  • Employees: more than 250.
  • Balance sheet total: more than SEK 280 million.
  • Net turnover: more than SEK 550 million.

A search of the Riksdag's documents on 21 October 2026 found no government bill transposing the Omnibus.23

Takeaway: plan to the EU dates, but check national law before each cycle: on 21 October 2026, Sweden's law still used the old thresholds. If you report in Germany or the Netherlands, ask your auditor which rules apply for 2026, since neither has transposed the original CSRD.

Chapter 5

Out of scope: use the voluntary standard, and know what customers can require

Companies outside the CSRD can still be asked for sustainability information by customers that report. The Omnibus answers this with a common format and a limit. The format is the voluntary standard, built on the earlier VSME recommendation, and the limit is the value chain cap for companies with 1,000 employees or fewer.1,10

1,000

employees or fewer: protected from extra CSRD requests

2027

first financial year the value chain cap applies

2

disclosures on practices and policies outside the cap: B2 and C2

The voluntary standard replaced the VSME recommendation on 24 September 2026

The VSME, a voluntary reporting standard for small and medium-sized companies, began as Commission Recommendation (EU) 2025/1710 of 30 July 2025.10 The Omnibus required the voluntary standard to build on that original version, and the Commission adopted it on 3 July 2026 as Delegated Regulation (EU) 2026/1560.1,10 Published on 21 September 2026, it entered into force on 24 September 2026, when the recommendation stopped producing legal effects.10

Companies that apply the voluntary standard are not obliged to obtain assurance on what they report.10 B2 covers practices, policies and future initiatives, including what a company does to reduce negative and enhance positive impacts on people (Annex I, paragraph 30).10 Community partnerships and giving can be described there, although the standard names only partnerships related to sustainability projects as an example.10

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What it covers What your programmes supply Reference
Practices, policies and future initiatives, including what you do to enhance positive impacts on people10 Whether you run community partnerships, volunteering or donations, whether the policies exist and are public, planned initiatives and targets B2, paras 29 and 30
A brief description of each practice, whether it covers suppliers or clients, its targets and, optionally, the accountable senior level10 A short description of each community programme reported under B2 C2, paras 47 and 48
The only datapoints a CSRD customer can require from a protected undertaking10 Nothing: B2 and C2 are not on the list, so sharing them is voluntary Annex II

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The workbook's VSME (B2, C2) sheet has five columns for exactly these items: the practice, its description, supplier or client coverage, future initiatives and targets. A company that leaves the CSRD can keep its quarterly collection and simply report less.

The value chain cap: what a CSRD customer can and cannot require

From financial year 2027, value-chain companies with 1,000 employees or fewer, called protected undertakings, may refuse CSRD reporting requests that go beyond the voluntary standard.1,10 The cap list sits in Annex II of the regulation and does not include B2 or C2. A CSRD reporter therefore cannot require community programme information from a protected undertaking for CSRD purposes.10

  • Self-declared size counts. The reporting company may rely on a partner's own statement of its size, unless that statement is manifestly incorrect.1
  • Extra questions must be flagged. A request that goes beyond the standard must say which items exceed it and that the partner has a statutory right to decline.1
  • Only CSRD requests are capped. Requests for other purposes, such as due diligence, are not limited by the cap.1
  • Finland has written the cap into national law. There, a reporting company may not contractually require more than the voluntary standard from a value-chain company with no more than 1,000 employees on average.22

A smaller company can report its community programmes in B2 and C2 and share them with customers by choice, not by obligation. A CSRD reporter that wants this data must ask for it as a voluntary request and state the right to decline.10,1

Takeaway: if you are out of scope, keep collecting the same programme data and describe it in B2 and C2 if you report voluntarily. If you are a CSRD reporter, ask smaller partners for community data as an optional request, and say they may decline.

Readiness check

Check your readiness

Tick each row your team can already answer for financial year 2026. The rows follow the order of the work, from the scope test to the political screen, and each comes from a rule in Chapters 1 to 5. A missing tick therefore points to the chapter that explains the fix.

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Check What the rules ask You
Scope test From financial year 2027, EU companies and groups report only above both €450 million net turnover and 1,000 employees.1 Have you run the test for your company and your group, and do you know which financial years you report for?
ESRS version for 2026 A financial year 2026 statement must say which ESRS version it applies.5 If you report for 2026, have you chosen and recorded yours? If you do not report for 2026, tick this row.
Materiality S3, S1 and G1 are reported only if material.5 Have you assessed affected communities, own workforce and political influence?
Programme register Key actions need their scope: entity, country, site and community groups.5 Is every programme listed once with these fields?
Spend traced to the accounts Significant resources need their financial-statement line items or notes.5 Can you map each programme total to the ledger?
Volunteering time Significant staff time can be shown as FTE, and S1-5 headcount gives a consistent denominator for participation rates.5 Do you hold hours by programme and country?
Metric definitions Every programme metric needs a definition, unit and calculation method.5 Are yours written down?
Political screen Donations and sponsorships to parties, elected representatives or candidates are political contributions.5 Is every recipient screened before payment?

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Your score sorts you into three bands

  • 7-8: your data is in shape, whatever your scope and materiality results. Keep the quarterly routine, and review materiality each year before you decide what to publish.
  • 4-6: the structure is there, so close any ledger and screening gaps first. Both rows depend on people outside the CSR team, in finance and among approvers, so start on them early.
  • 0-3: start with the register. One row per programme, with entity, country and community groups, is the base for every other check.
FAQ

Frequently Asked Questions

Does the CSRD still apply to my company after the Omnibus?
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When do the revised ESRS apply?
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Do I still have to report employee volunteering under the CSRD?
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Are corporate donations and sponsorships political contributions under ESRS?
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Can a CSRD customer require community data from a smaller supplier?
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One place for programmes, spend, volunteering hours and reporting

Optimy gives companies and corporate foundations one platform for their community programmes: grant and donation requests, sponsorships and employee volunteering. Each programme keeps its entity, country, spend, hours and outcomes in one record, so the quarterly collection and the year-end report draw on the same data.

Methodology & sources

This guide summarises published EU texts and national legislative records as of 21 October 2026 and is not legal advice. Check the final texts, and the law of each country where you report, with your auditor or legal adviser before you rely on them.

Every rule, date and threshold comes from the official source listed below: the Official Journal of the EU, the European Commission, EFRAG, the EU Publications Office and national parliaments and gazettes. Each was checked again against that source on 21 October 2026. Where a point could only be partly confirmed, the sentence that uses it names its provision and states the caveat. The ESRS do not name community investment, volunteering, donations or sponsorship outside G1-5, so linking a programme to a datapoint is a reporting choice, and the guide says so where it applies. The companion workbook carries the ESRS reference and status of every column, taken from the same verified research.

  1. Directive (EU) 2026/470 of 24 February 2026 (Omnibus I), amending the Accounting Directive and the CSRD, Official Journal of the EU, 26 February 2026 · eur-lex.europa.eu/eli/dir/2026/470/oj
  2. Directive (EU) 2025/794 of 14 April 2025 (stop-the-clock), Official Journal of the EU, 16 April 2025 · eur-lex.europa.eu/eli/dir/2025/794/oj
  3. Directive (EU) 2022/2464, the Corporate Sustainability Reporting Directive (CSRD), Official Journal of the EU, 16 December 2022 · eur-lex.europa.eu/eli/dir/2022/2464/oj
  4. Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 (wave-one quick fix to the ESRS), Official Journal of the EU, 10 November 2025 · eur-lex.europa.eu/eli/reg_del/2025/1416/oj
  5. Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 (revised ESRS, including ESRS 1, ESRS 2, S1, S3 and G1), Official Journal of the EU, 21 September 2026 · eur-lex.europa.eu/eli/reg_del/2026/1563/oj
  6. European Commission, DG FISMA, "Commission adopts revised sustainability reporting standards to reduce administrative burdens for EU businesses while maintaining high-quality disclosures" (3 July 2026) · finance.ec.europa.eu/news/commission-adopts-revised-sustainability-reporting-standards-reduce-administrative-burdens-eu-2026-07-03_en
  7. EFRAG, "EFRAG provides its technical advice on draft simplified ESRS to the European Commission" (3 December 2025) · www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission
  8. EFRAG, "European Commission adopts revised ESRS and Voluntary Sustainability Reporting Standard" (22 September 2026) · www.efrag.org/en/news-and-calendar/news/european-commission-adopts-revised-esrs-and-voluntary-sustainability-reporting-standard-efrag
  9. Commission Delegated Regulation (EU) 2023/2772 (first set of ESRS, 2023), Official Journal of the EU, 22 December 2023 · eur-lex.europa.eu/eli/reg_del/2023/2772/oj
  10. Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026 (voluntary standard and value chain cap), Official Journal of the EU, 21 September 2026 · eur-lex.europa.eu/eli/reg_del/2026/1560/oj
  11. EU Publications Office, national implementing measures for Directive (EU) 2022/2464: France, Ordonnance n° 2023-1142 of 6 December 2023 · publications.europa.eu/resource/cellar/c615dbfc-c85c-43b9-ac7a-4ee4c9f83f05
  12. EU Publications Office, national implementing measures for Directive (EU) 2025/794: France, Loi n° 2025-391 of 30 April 2025 · publications.europa.eu/resource/cellar/709942c1-60c7-465b-b997-9072ab994453
  13. Sénat, legislative file pjl25-118 (bill adapting French law to EU law, Senate text n° 118, with the CSRD scope changes in its Article 9) · www.senat.fr/dossier-legislatif/pjl25-118.html
  14. Deutscher Bundestag, DIP procedure 325513, government bill implementing Directive (EU) 2022/2464 (Drucksache 21/1857) · www.bundestag.de/dip-api/api/v1/vorgang/325513?format=json
  15. Deutscher Bundestag, Legal Affairs Committee (Rechtsausschuss), public hearing of 13 April 2026 on Drucksachen 21/1857 and 21/2465 (committee page) · www.bundestag.de/ausschuesse/recht-verbraucherschutz/sitzungen/1158028-1158028
  16. Deutscher Bundestag, Drucksache 21/7745, written answer of 27 August 2026 · dserver.bundestag.de/btd/21/077/2107745.pdf
  17. Deutscher Bundestag, Drucksache 21/6244, written answer of 2 June 2026 · dserver.bundestag.de/btd/21/062/2106244.pdf
  18. Tweede Kamer der Staten-Generaal, open data record for bill 36678 (Wet implementatie richtlijn duurzaamheidsrapportering), committee decision of 12 February 2026 · gegevensmagazijn.tweedekamer.nl/OData/v4/2.0/Zaak?$filter=Nummer%20eq%20'2025Z00251'&$expand=Besluit
  19. EU Publications Office, national implementing measures for Directive (EU) 2022/2464: Belgium, law of 2 December 2024 · publications.europa.eu/resource/cellar/968fdcf4-8b0b-4fbe-b7d9-a874fc5346e8
  20. Moniteur belge, Loi du 12 décembre 2025 modifiant l'article 116 de la loi du 2 décembre 2024 (published 23 December 2025) · www.ejustice.just.fgov.be/eli/loi/2025/12/12/2025009725/moniteur
  21. Moniteur belge, Loi du 15 juillet 2026 modifiant l'article 116 de la loi du 2 décembre 2024 (published 31 July 2026) · www.ejustice.just.fgov.be/eli/loi/2026/07/15/2026005819/moniteur
  22. Finlex, Act 555/2026 amending the Accounting Act (in force 30 June 2026) · www.finlex.fi/sv/lagstiftning/forfattningssamling/2026/555
  23. Riksdagen open data, Årsredovisningslag (1995:1554), consolidated up to SFS 2026:780 · data.riksdagen.se/dokument/sfs-1995-1554.text
  24. EU Publications Office, national implementing measures for Directive (EU) 2025/794: Denmark, Act 1636 of 16 December 2025 · publications.europa.eu/resource/cellar/cff7929e-acb1-4b64-94e7-aa8ff0f23f66
  25. Folketinget open data, bill L 7 (2026-27) amending the Financial Statements Act to implement the Omnibus Directive · oda.ft.dk/api/Sag(106018)?$format=json

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About Optimy

Optimy is the platform that companies and corporate foundations use to run grant, donation, sponsorship and volunteering programmes, from application to reporting. optimy.com

© 2026 Optimy · You may quote this guide with attribution ("Optimy, CSRD after the Omnibus: the community data you still need") and a link to the source page.