Regulatory Alerts
EU CSRD: What It Means for Non-EU Companies Selling Into Europe
A note on timing. Regulatory thresholds, deadlines, and litigation outcomes referenced below are moving targets. This post reflects research current to mid-2026 and flags what's still in flux. It's written for a general business audience and is not legal advice — confirm current requirements with counsel or the relevant regulator before making compliance decisions.
If you looked into CSRD a year or two ago and concluded your company was in scope, it's worth checking again. The rules changed significantly in early 2026, and a lot of companies that expected to be reporting soon no longer are — for now.
What CSRD is, in one sentence
The Corporate Sustainability Reporting Directive requires large companies with meaningful EU activity to publish detailed sustainability disclosures — covering environmental, social, and governance topics, including Scope 1, 2, and 3 emissions — audited to a common EU standard.
The big 2026 change: the "Omnibus" simplification
In response to business pressure over cost and complexity, the EU passed a sweeping simplification package (known as "Omnibus I"), which was signed into law in February 2026 and took effect on March 18, 2026. It cut the number of in-scope companies by roughly 90%. If you assessed your CSRD exposure before that date, treat that assessment as outdated.
Who's actually in scope now, if you're not an EU company
Post-Omnibus, a non-EU parent company is only pulled into CSRD if it meets both of these, for two consecutive financial years:
- More than €450 million in net turnover generated within the EU, and
- An EU subsidiary or branch with more than €200 million in net turnover in the preceding year
If you clear both thresholds, your obligation starts for financial years beginning on or after January 1, 2028, with your first report published in 2029.
That's a meaningfully higher bar than the original rules (which caught companies at €150 million EU turnover with a €40 million branch threshold). A lot of mid-sized exporters and manufacturers who were bracing for CSRD compliance are now genuinely out of scope — at least until the next review clause potentially widens it again.
Don't stop paying attention if you're just under the threshold
A few reasons this still matters even if you're not directly caught:
- The review clause is real. The Omnibus text explicitly allows the EU to revisit and expand scope later. Thresholds you're comfortably under today aren't guaranteed to stay there.
- Indirect exposure through customers. If you sell to a company that is in CSRD scope, they may still ask you for emissions and sustainability data to fill in their own Scope 3 disclosures — regardless of whether you're directly regulated.
- Value-chain data requests are capped, but not eliminated. Under the revised rules, in-scope companies generally can't demand more from small suppliers (under 1,000 employees) than a simplified voluntary standard already covers — which limits, but doesn't remove, the trickle-down data requests.
What to actually do in 2026
- Re-run your scoping exercise. If your last CSRD assessment predates March 2026, it's stale.
- Identify your EU subsidiary/branch structure. The rule hinges on where your EU turnover sits, not just your global size — a company with a small EU subsidiary and centralized sales might land differently than expected.
- Watch for customer-driven Scope 3 requests, which will likely arrive well before any direct regulatory obligation does.
- Don't tear down what you've already built. If you started CSRD preparation before the Omnibus changes, that data infrastructure isn't wasted — it's exactly what most other regimes (ISSB-aligned frameworks, UK SRS, GCC disclosure rules) will eventually ask for too.
Carbon Logger tracks Scope 1, 2, and 3 data in a structure that maps cleanly to CSRD, ISSB, and GCC disclosure formats — so if your obligations shift, your underlying data doesn't need to be rebuilt.