CSRD Omnibus Scope Check 2027 by ReadyStack

Directive (EU) 2026/470 replaced the two-of-three test with one AND test. This tells you which side of it you landed on.


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• The AND test, not two-of-three — Directive (EU) 2026/470 replaced the old 250 FTE / 50m turnover / 25m balance-sheet two-of-three test with a single cumulative test: more than 1000 FTE AND more than 450m net turnover. Balance sheet total is no longer a leg. A company at 780 FTE and 310m turnover is OUT OF SCOPE even though it passed two of the old three.
• Three entry doors judged separately — An EU company or group is judged on 1000 FTE AND 450m. An EU-listed small or medium company is struck out of CSRD outright with no size test. An EU arm of a non-EU parent is judged on EU net turnover over 450m AND one subsidiary or branch over 200m.
• The gap before national law exists — Omnibus I entered into force 2026-03-18 and member states have until 2027-03-19 to transpose it. A financial year starting 2027-01-01 therefore runs 77 days before the national rule it is supposed to follow is even on the statute book.
• Budget you can stand down — Member states may exempt former wave 1 companies for financial years starting between 2025-01-01 and 2026-12-31. With that option enacted, an out-of-scope company drops 3 reporting years of ESRS prep and limited assurance. At a budgeted 180 thousand per year that is 540 thousand.
• Export and diary (full version) — The full version writes the verdict, the deciding leg and the dated inputs to a .csv you can put in the audit file, and sets a browser alarm for the 2027-03-19 transposition deadline so you re-run the test when your member state publishes.

| You type | |
|---|---|
| Which door do you come in by | default EU company or group (standalone or consolidating parent) |
| Average employees over the year | default 780 |
| Net turnover (EU turnover if you came in by the non-EU parent door) | default 310 |
| Balance sheet total | default 240 |
| Largest single EU subsidiary or branch turnover (non-EU parent door only) | default 0 |
| First financial year you are budgeting for (YYYY-MM-DD) | default 2027-01-01 |
| Your budgeted ESRS prep plus limited assurance for one reporting year | default 180 |
| My member state enacted the optional FY2025 to FY2026 exemption | default True |

| It answers | |
|---|---|
| Verdict under Directive (EU) 2026/470 | |
| The leg that decided it | |
| First mandatory reporting year | |
| Days your FY runs before the 2027-03-19 transposition deadline | days |
| Reporting years you can stand down | years |
| Budget you can stand down | thousand EUR |

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