In the flood of articles, posts and alerts about the recent Omnibus proposal, changes in non-EU reporting obligations have been lost in the shuffle. The CSRD calls for enterprise-wide level reporting for certain companies with a large presence in the EU. While not in the Omnibus’s main summary, there are serious scoping changes in the proposal to the EU Accounting Directive:
“… paragraph (12) amends Article 40a(1) of the Accounting Directive by:
- limiting the size for a subsidiary undertaking to be in scope of Article 40a to the criteria for large undertakings as defined in Article 3(4) of the Accounting Directive;
- increasing the net turnover threshold for a branch to be in scope of Article 40a from EUR 40 million to EUR 50 million, to align with the turnover threshold for large undertakings;
- increasing the net turnover threshold for the third-country undertaking to be in scope of Article 40a from EUR 150 million generated in the Union to EUR 450 million;”
This means that for a non-EU company to fall within the scope of the CSRD, it will need both:
- An annual turnover of at least EUR 450 million in the EU for the past two years, AND either
- a large EU subsidiary subject to CSRD or;
- a branch in the EU with a net turnover of EUR 50 million.
However, while scoping requirements have been altered, timeframes for non-EU company reporting are unchanged. Non-EU companies subject to the CSRD will still be expected to report on their fiscal year 2028 data in 2029.
Our members can learn more about CSRD reporting here.
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