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 | — | |
|---|---|---|
| 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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The European Commission puts the recurring CSRD administrative cost that this directive removes at EUR 4.4 billion a year across the companies it exempts, plus about EUR 1.6 billion in one-off savings. Finding your own share of th
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Real numbers from this tool, line by line.
A group financial controller in Stuttgart stood down 540 thousand EUR of ESRS budget in one afternoon: 780 FTE, 310 million EUR net turnover, 180 thousand EUR a year of prep and assurance — OUT OF SCOPE under Directive (EU) 2026/470.
That directive, Omnibus I, was published in the Official Journal on 2026-02-26 and entered into force on 2026-03-18. It replaced the door.
The old CSRD entry test was two of three: 250 employees, 50 million EUR net turnover, 25 million EUR balance sheet total. Meet any two and you reported. The new test is a single cumulative AND: more than 1000 FTE AND more than 450 million EUR net turnover. The balance-sheet leg is not reduced, it is deleted. And it bites on financial years beginning on or after 2027-01-01.
Run the Stuttgart numbers through the old test and the company is in: 780 FTE clears 250, and 240 million EUR of balance sheet clears 25 million. Two of three. Run them through the new one and both legs miss at once, because the balance sheet is no longer a leg at all.
The trap is that the new test is AND, not OR. A company at 1200 FTE — comfortably over the headcount gate — with 310 million EUR of turnover is still out, 140 million short of the other leg. Anyone who read "1000 employees" in a headline and stopped there has it backwards.
There are three doors, judged separately. An EU company or consolidating parent is judged on 1000 FTE AND 450 million. An EU-listed small or medium company is struck out of CSRD outright, with no size test run on it at all. An EU arm of a non-EU parent is judged on EU net turnover over 450 million EUR AND one subsidiary or branch over 200 million EUR: a US group with 900 million EUR of EU turnover and a 310 million EUR Dutch subsidiary is in scope, having never filed an ESRS report.
Then there is the gap almost nobody has budgeted for. Member states have twelve months from 2026-03-18 to transpose Omnibus I, which sets the deadline at 2027-03-19. A financial year that starts on 2027-01-01 therefore runs 77 days before the national text it is supposed to comply with is even on the statute book. A year starting 2027-04-01 lands on the other side of it, by 13 days.
There is also an option worth real money. Member states may exempt former wave 1 companies for financial years starting between 2025-01-01 and 2026-12-31. Where that option is enacted and you are out of scope, three reporting years come off the plan rather than one. At 180 thousand EUR a year, that is the 540 thousand in the first line.
This needs a tool rather than a chatbot because of dating. Almost every free answer in circulation predates 2026-03: two-of-three test, wave 2 reporting in 2026, balance sheet still a leg. It fails in both directions, telling an in-scope third-country group it is clear and an exempt Mittelstand company to keep paying.
CSRD Omnibus Scope Check 2027 is a browser extension and a free web page running the same code. You enter eight figures — door, headcount, net turnover, balance sheet, largest EU arm, financial year start, annual ESRS budget, and whether your member state enacted the relief option. It returns six: the verdict, the deciding leg in your own numbers, your first mandatory financial year, the days to 2027-03-19, the reporting years you can stand down, and the budget that represents.
All of that is free, with no key and no run limit. The 60 dollar full version sits on a different axis: it exports each dated run as a .csv for the audit file, and sets a browser alarm on 2027-03-19 so you re-run the test against your own national text the week it publishes.
You enter your average headcount, net turnover, balance sheet total and which door you come in by. It runs the scope test as Directive (EU) 2026/470 rewrote it, which is more than 1000 FTE AND more than 450 million net turnover, then tells you in words which leg decided the answer and which financial year your first mandatory report covers.
Group financial controllers, CFOs and sustainability leads at EU companies between roughly 250 and 1500 employees who built a CSRD programme under the old rules, and at EU subsidiaries and branches of non-EU parents. If you were called wave 1, wave 2 or a listed SME before 2026, you are the customer.
Models trained before March 2026 still answer with the old two-of-three test of 250 employees, 50 million turnover and 25 million balance sheet, and still put wave 2 first reports in 2026. Omnibus I made the test cumulative, deleted the balance-sheet leg and pushed the new scope to financial years beginning on or after 2027-01-01.
Every calculation is free forever, with no key, no watermark and no run limit. The 60 dollar key adds two things on a different axis: a dated .csv export of each run for your audit file, and a browser alarm on the 2027-03-19 transposition deadline that tells you to re-run the test against your national text.
Establishing your post-Omnibus scope position is normally a paid engagement with an accounting or ESG advisory firm. The European Commission estimates the directive removes 4.4 billion euro a year of recurring CSRD administrative cost plus about 1.6 billion in one-off cost across the companies it exempts, so the question is worth asking properly.
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