CSRD Thresholds

CSRD Thresholds

January 8, 2026
CSRD Thresholds

The Corporate Sustainability Reporting Directive (CSRD) establishes comprehensive CSRD thresholds that determine which companies must comply with enhanced sustainability reporting requirements across European markets. These requirements affect approximately 50,000 companies globally, with recent regulatory changes introducing significant modifications to threshold calculations. European companies and international organisations with substantial EU operations must navigate these evolving CSRD thresholds to ensure compliance with sustainability reporting obligations. Understanding these requirements becomes critical for businesses, particularly as regulatory frameworks continue developing. Iceberg Data Lab's expertise in ESG data solutions supports organisations worldwide in navigating these complex regulatory landscapes through scientifically robust methodologies and comprehensive sustainability analytics.

Understanding CSRD Threshold Criteria and Recent Updates

Core Threshold Framework

The CSRD establishes a three-tier system for large undertakings, requiring organisations to meet at least two of three specific criteria during consecutive financial years. The balance sheet threshold requires total assets exceeding €25 million, increased from €20 million to reflect inflationary adjustments. The net turnover criterion establishes €50 million as the revenue threshold, whilst the employees requirement maintains 250+ staff on average during the financial year. This criteria ensures companies with substantial operational scale and potential environmental impact fall within the directive's scope. Large undertakings must satisfy this two-out-of-three principle, preventing circumvention through narrow interpretation of individual criteria.

2023-2025 Regulatory Changes

The European Commission implemented significant threshold adjustments in October 2023, specifically targeting balance sheet and turnover criteria to address inflation effects. These modifications reduced companies classified as significant from approximately 82,986 to 71,372, representing targeted reduction whilst maintaining directive effectiveness. Recent omnibus proposals in 2025 introduce even more dramatic changes, potentially redefining large undertakings as organisations with over 1,000 employees. This new framework would eliminate 80% of companies from mandatory CSRD coverage, fundamentally altering the regulatory landscape. These reporting requirements will undergo European parliamentary scrutiny before implementation, with thresholds potentially increasing substantially for affected organisations.

Implementation Timeline and Company Categories

The CSRD follows a structured four-phase implementation designed to ensure systematic coverage expansion across different company categories. Phase one, effective January 2024, targets large public interest entities with over 500 employees previously subject to non-financial reporting requirements. Phase two implementation, beginning January 2025, extends coverage to all other large undertakings not previously covered. The third phase commences January 2026, bringing listed SMEs into the framework for the first time, representing significant expansion of sustainability reporting requirements to smaller public companies. Phase four implementation begins January 2028, completing coverage by including non-EU companies with significant European operations. This phased approach enables learning opportunities whilst maintaining regulatory objectives for comprehensive sustainability reporting coverage. Corporate entities must prepare financial report submissions according to these structured timelines, with directive compliance becoming mandatory across all phases.

Strategic Compliance with Iceberg Data Lab Solutions

Organisations subject to CSRD thresholds must develop comprehensive compliance strategies addressing current requirements whilst maintaining flexibility for potential regulatory changes. Double materialityassessment processes require evaluation of both financial impacts on companies and company impacts on society and environment. Iceberg Data Lab's scientific methodologies support organisations globally through robust data management capabilities and advanced analytics tools. Digital reportingrequirements mandate machine-readable sustainabilityinformation using standardised formats, creating new implementation thresholds related to system capabilities. Business entities must invest in technological infrastructure supporting both internal data management needs and external reporting obligations. Professional services encompass materialityassessment guidance, data quality standards, and comprehensive sustainability analytics that enable effective compliance strategies. These information management services ensure organisations maintain regulatory compliance whilst supporting broader sustainability objectives and stakeholder expectations across global markets.

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