Free access to all five chapters, the readiness check, all 25 verified sources and the ten-sheet workbook, which you fill in on the page and download as an Excel file.
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.

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