Templates and records · Sustainability
CSRD scope assessment template after the Omnibus
The check, with figures and a date, of whether the company or group falls under the reporting obligation, and from which financial year.
In one sentence
The CSRD scope assessment documents the average headcount and net turnover of the company or group, compares them with the thresholds of Directive (EU) 2026/470 —more than 1,000 employees and more than €450 million— and concludes from which financial year reporting is required; it is good practice, since the directive does not call for this record but the board must be able to justify its decision.
- Type of information
- Good practice Good practice: the obligation stems from Directive (EU) 2022/2464 as amended by 2026/470
- Who fills it in
- Finance department with legal counsel The conclusion is validated by the board of directors
- When
- At each financial year end And whenever the transposing law or the group structure changes
- How long it is kept
- At least while the report can be reviewed Neither the directive nor the ESRS set a period for working papers; it is wise to keep them with the management report for the year and those for the comparative year.
What the standard requires
What Sustainability demands and what it leaves to your judgement
Directive (EU) 2026/470 narrowed the scope of the CSRD to companies with net turnover above €450 million and an average of more than 1,000 employees during the financial year. For groups, the consolidated whole is considered, and third-country groups are subject to the same turnover figure within the Union.
The first wave of companies is limited to financial years starting between 1 January 2024 and 31 December 2026, and Member States may exempt those that do not exceed the new thresholds from reporting on 2025 and 2026. From financial years starting in 2027, companies outside the new scope are no longer subject to it.
How it applies in practice depends on the national transposing law. That is why the assessment must be dated and reviewed once the law is published.
Structure
Fields the template should include
- Company or group assessed and financial year
- Average headcount for the year and calculation method
- Net turnover, individual or consolidated
- Thresholds applied and the rule that sets them
- Position in the first wave, if applicable
- Conclusion: in scope, out of scope or pending transposition
- Date, owner and next review
Example
Example: mid-sized food group (fictitious group)
Company, people and figures are fictitious: the example only shows what a properly completed record looks like.
| Field | Content |
|---|---|
| Group | Talbot Foods Group (fictitious) · financial year 2025 |
| Average headcount | 1,450 employees, calculated as the average of the twelve monthly headcounts |
| Consolidated turnover | €610 million |
| Thresholds | More than 1,000 employees and more than €450 M (Directive (EU) 2026/470) |
| Conclusion | Exceeds both thresholds: required to report on financial year 2027 under the law transposing the directive |
| Subsidiary with 120 employees | Does not report separately: covered by the consolidated report |
| Review | Board of directors, 24 February 2026 · to be reviewed once the Spanish law is published |
At the audit
Mistakes auditors commonly flag
- Pre-Omnibus thresholds are still being applied.
- Headcount is taken at a single date instead of as the average for the year.
- No distinction between the parent company’s obligation and that of its subsidiaries.
- The assessment is undated and nobody reviews it when the rules change.
In Kimobox
How this record is kept in Kimobox
- 1The assessment is documented as a versioned record, with its date and owner.
- 2The governance structure and board decisions are kept as controlled documents.
- 3The review schedule is set up with a reminder to the owner.
Frequently asked questions
What people ask us before getting started
What if only one of the two thresholds is exceeded?
After Directive (EU) 2026/470, both must be exceeded: more than 1,000 employees and more than €450 million in net turnover.
Can a company outside the scope still report?
Yes, voluntarily. For undertakings protected by the value-chain cap there is the voluntary standard in Delegated Regulation (EU) 2026/1560.
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Sources
Where each figure comes from
References to the official text in force. If a standard is revised, this page is updated and the review date says so.
- Directive (EU) 2026/470 amending Directive (EU) 2022/2464 as regards sustainability reporting and due diligence requirements EUR-Lex · 26 February 2026
- Directive (EU) 2022/2464 on corporate sustainability reporting (CSRD) EUR-Lex · 14 December 2022
- Directive (EU) 2025/794 postponing certain sustainability reporting dates EUR-Lex · April 2025
- Delegated Regulation (EU) 2026/1560, voluntary sustainability reporting standards for undertakings protected by the value-chain cap EUR-Lex · OJ of 21 September 2026