1. CSRD before and after Omnibus I
The Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464) ("CSRD") was originally drafted with thresholds of 250 employees / €40M turnover. Omnibus I (Directive (EU) 2026/470, in force 18 March 2026) materially narrowed the in-scope population.
The locked wording: CSRD Omnibus I narrowed in-scope companies to those with both >1,000 employees AND >€450M turnover (both required). The checker uses this post-Omnibus I threshold as the canonical test. The old thresholds are not relevant to new applicability assessments.
2. The three-layer engine
The checker runs three sequential layers:
- Layer 1, mandatory scope: does the entity meet the post-Omnibus I threshold (both criteria)? Includes EU subsidiaries of non-EU parents and EU-listed entities.
- Layer 2, forward risk: is the entity below threshold today but on a trajectory to cross it within the next 24 months? This matters for medium-term planning and audit readiness.
- Layer 3, value chain: is the entity a material element of an in-scope group's value chain, such that ESRS 1 double-materiality may pull it into reporting?
3. Group-consolidation rules
Where an entity is a subsidiary of a larger group, the checker applies the consolidation test on the parent. The parent reports on a consolidated basis under article 19a; the subsidiary may be exempted from individual reporting under the parent-undertaking exemption, subject to disclosure requirements in the subsidiary's management report.
4. Counting employees
"Employees" means the average number of employees during the financial year, calculated on a consolidated basis. The checker uses the employees figure as filed in audited annual statements where available; otherwise the user enters the figure manually.
5. Counting turnover
"Turnover" means consolidated net turnover expressed in euros. The checker performs FX conversion using the European Central Bank rate at year-end. For non-euro reporters, the user can either enter the original-currency figure or the euro-equivalent.
6. The "both required" rule
This is the single most-mistaken element. Pre-Omnibus, the test was an "either-or" combination across 3 criteria. Post-Omnibus, it is "both required" on the two headline criteria (employees AND turnover). The balance-sheet test is no longer the gating factor.
7. The VSME alternative for SMEs
The locked wording: EFRAG VSME (2024) is the SME-friendly path. Entities that fall outside the post-Omnibus threshold can use VSME for voluntary sustainability reporting that is appropriate to their size and audit risk.
8. What the checker does not do
It does not give legal advice. It does not run a full ESRS data point inventory. It does not produce the limited-assurance pack. The full CrowESG platform (Coming Q3 2026) extends to multi-framework reporting, double-materiality assessment, and audit-ready evidence trail.
9. References
- Directive (EU) 2022/2464 (CSRD).
- Directive (EU) 2026/470 (Omnibus I), in force 18 March 2026.
- EFRAG, European Sustainability Reporting Standards (ESRS).
- EFRAG, VSME Standard (2024).