Directive (EU) 2026/470 replaced the two-of-three test with one AND test. This tells you which side of it you landed on.
Verdict under Directive (EU) 2026/470
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The leg that decided it
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First mandatory reporting year
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Days your FY runs before the 2027-03-19 transposition deadline
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days
Reporting years you can stand down
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years
Budget you can stand down
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thousand EUR
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.