Physical climate risk data,
ready for CSRD.
The directive shrank. E1-9 didn't. After Omnibus I (Directive (EU) 2026/470), CSRD now applies only to companies with 1,000+ employees and €450m+ turnover. The simplified ESRS cut datapoints by ~60%. Double materiality, climate disclosure and E1-9 financial effects survived intact.
CSRD is the EU's mandatory sustainability disclosure regime. After Omnibus I (Directive (EU) 2026/470, in force 18 March 2026), it applies to roughly 6,000 of the largest EU undertakings under the simplified ESRS, with double materiality, climate disclosure and the E1-9 financial-effects test all retained.
EU companies with 1,000+ employees AND €450m+ net turnover. Non-EU parent groups with €450m+ EU turnover (with a subsidiary or branch over €200m). Listed SMEs fully exempt. First reports under the new framework cover FY2027 (lodged 2028). Wave 1 reporters continue under existing rules through FY2026.
CSRD is the law. ESRS is the rulebook.
CSRD requires sustainability disclosure under EU law. ESRS specifies what to disclose. Both got simplified by Omnibus I in February 2026, narrowing scope from ~50,000 companies to roughly 6,000 of the largest, and cutting mandatory datapoints by ~60%. The hard core stayed.
60% fewer datapoints. The hard ones stayed.
Omnibus I cut datapoints by roughly 60%, killed sector-specific standards, removed the move to reasonable assurance, and dropped the Paris Agreement compatibility wording on transition plans. What it didn't touch: double materiality, climate disclosure, the E1-9 financial-effects test, and the asset-level data they all depend on.
Two perspectives. One assessment.
Impact materiality (how the company affects people and the environment) and financial materiality (how sustainability matters affect the company) both remain mandatory. Omnibus I streamlined the documentation. It didn't dilute the dual lens.
E1-9 isn't on the cutting list.
The simplified ESRS slim narrative content and remove voluntary datapoints. They don't cut the anticipated financial effects of physical and transition climate risk. Quantified euros, by horizon, by material asset. Same data demand as before.
Local laws, not EU law direct.
Directives bind member states to a result, not a method. Each EU country transposes CSRD into national law with local variations on lodgement, supervisor, penalties. Multinationals win when the data spine carries every transposition.
The CSRD framework: 7 chapters across two directives and one regime.
CSRD as it stands today is the outcome of three legislative acts: the original 2022 directive, the Stop-the-Clock postponement in 2025, and Omnibus I in early 2026. Click each section to unpack what now applies, what's been simplified, and what's coming.
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Chapter 1: Legal architecture
Three directives. One regime.
CSRD lives across three legislative acts. The 2022 directive set up the framework, Stop-the-Clock delayed waves 2 and 3 in April 2025, and Omnibus I narrowed scope and simplified content in February 2026.
- Original CSRD: Directive (EU) 2022/2464, adopted December 2022
- Stop-the-Clock: Directive (EU) 2025/794, postponed waves 2 and 3 by two years
- Omnibus I: Directive (EU) 2026/470, in force from 18 March 2026
- Replaced NFRD (Directive 2014/95/EU) which captured ~11,000 companies
- Member states have 12 months to transpose Omnibus I provisions
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Chapter 2: Scope post-Omnibus
From ~50,000 to ~6,000 companies.
Omnibus I dramatically narrowed CSRD scope. The wave system is gone. Only the largest EU undertakings, plus equivalent non-EU groups, remain in scope.
- EU companies: 1,000+ employees AND €450m+ net turnover
- Non-EU parents: €450m+ EU turnover, with subsidiary or branch over €200m
- Listed SMEs: fully exempt (was original Wave 3)
- Wave 1 transition: continue reporting through FY2026 even if now out of scope
- Member states may grant exemption for former Wave 1 companies, country by country
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Chapter 3: Double materiality
Two perspectives. One assessment.
Double materiality is the foundation CSRD rests on, and Omnibus I left it intact. Companies must assess sustainability matters from two angles: the inside-out impacts the company has, and the outside-in financial effects on the company.
- Impact materiality: how the company affects people and the environment
- Financial materiality: how sustainability matters affect cash flows, financing, cost of capital
- DMA process: stakeholder engagement, value chain consideration, time horizons
- Determines which topical ESRS apply (E1-E5, S1-S4, G1)
- Simplified Set 1 streamlines the methodology; the dual lens stays
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Chapter 4: ESRS connection
CSRD says report. ESRS says exactly what.
CSRD is the legal obligation. ESRS specifies the content. The simplified Set 1, due to be adopted within six months of Omnibus I entering into force, retains the structure and the hard climate disclosures.
- ESRS 1, ESRS 2 cross-cutting; E1-E5 environmental; S1-S4 social; G1 governance
- Mandatory datapoints reduced by approximately 60% in simplified Set 1
- Voluntary datapoints removed entirely
- Sector-specific ESRS: cancelled by Omnibus I
- E1 climate change retained substantially intact, including E1-9 financial effects
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Chapter 5: External assurance
Limited assurance, retained.
The original CSRD planned a move from limited to reasonable assurance. Omnibus I removed that escalation. Limited assurance is now the standing requirement, performed by the statutory auditor or an independent assurance services provider.
- Limited assurance from Year 1 of CSRD reporting
- Move to reasonable assurance: removed by Omnibus I
- Performed by statutory auditor or independent assurance services provider
- EU sustainability assurance standards being developed via CEAOB
- Specific assurance scope on the double materiality assessment
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Chapter 6: Filing & ESEF
Management report. XBRL tagged. ESAP.
Sustainability disclosures sit inside a dedicated section of the management report, machine-readable via ESEF (XBRL), and feed into the European Single Access Point (ESAP) when it goes live.
- Sustainability statement in a dedicated section of the management report
- ESEF (XBRL) tagging required for machine-readable filings
- European Single Access Point (ESAP): phased launch from mid-2027
- Lodged with national authorities, filing deadlines per member state law
- Audit signed by statutory auditor or independent assurance provider
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Chapter 7: Member state transposition
One directive. Twenty-seven local laws.
EU directives don't apply directly. Each member state transposes CSRD into national law with local variations on assurance providers, lodgement deadlines and penalties. The 12-month Omnibus I transposition window runs to roughly March 2027.
- 12 months from entry into force to transpose Omnibus I (deadline ~March 2027)
- National variations on lodgement deadlines, supervisors and penalties
- First-wave countries already had local CSRD laws (DE, FR, IT, ES, NL, others)
- Member states may exempt former Wave 1 companies from continued reporting
- Supervisors: AMF (FR), BaFin (DE), CONSOB (IT), CNMV (ES), AFM (NL), and equivalents
The simplification cut content. Not the climate test.
Omnibus I trimmed narrative and voluntary datapoints. The asset-level climate data underpinning double materiality, scenario analysis and E1-9 anticipated financial effects didn't move. If you're still in scope, the data challenge is the same as it was.
Double materiality assessment
Inside-out impacts and outside-in financial effects, both documented to a methodology that survives limited assurance. Omnibus I streamlined the documentation. The dual lens stays mandatory.
Asset-level physical climate risk
Asset-level exposure across real estate, supply chain nodes and operational facilities. Country averages don't survive limited assurance, and they don't underwrite a credible adaptation plan.
E1-9 anticipated financial effects
Quantified euro impact from material physical and transition climate risks, by short, medium and long-term horizon. The hardest disclosure in the standard, untouched by simplification.
Audit-grade methodology
Limited assurance from Year 1, retained as the standing requirement after Omnibus I. Every model, proxy and assumption must be defensible to the statutory auditor or independent assurance provider.
Physical climate risk data, built for CSRD double materiality and E1-9.
Spectra is the physical climate risk data platform behind CSRD disclosures at companies and financial institutions with over $13.5 trillion in combined AUM. Asset-level exposure across European and global portfolios, multi-pathway scenarios, audit-ready methodology, all in one place.
Asset-level exposure, 2bn+ assets
Material physical climate risk for every asset in scope. 11 hazards, building-level vulnerability, geolocation precision down to address and parcel. The granularity CSRD double materiality and E1-9 demand, without country averages.
Multi-pathway scenarios E1-9 expects
CMIP6 SSPs and CMIP5 RCPs covering low-warming and high-warming pathways. Short, medium and long-term horizons aligned to ESRS E1 strategic planning. NGFS scenarios for the financial sector view.
Hazard exposure to euros
Annual losses in monetary value, expected loss adjustments, business disruption risk and confidence intervals. The translation from physical hazard to anticipated financial effect that E1-9 requires, by horizon, by material asset.
Limited assurance ready
Model risk management aligned, ISO 27001 and ISO 14001 certified, full methodology documentation. Defensible to the statutory auditor or independent assurance services provider, and ready to feed parallel ISSB, AASB S2 and CSDS filings.
Are you ready for CSRD physical climate risk disclosure?
Pick your industry. The financial-effects question tailors itself to where physical and transition risk hits your sector hardest under E1-9.
CSRD readiness self-check
CSRD post-Omnibus: the questions disclosure leads actually ask.
What is CSRD?
CSRD is the EU's Corporate Sustainability Reporting Directive: the mandatory sustainability disclosure regime for large companies operating in the EU. Originally adopted in December 2022 as Directive (EU) 2022/2464 to replace the NFRD, it was substantially amended by Omnibus I (Directive (EU) 2026/470), in force since 18 March 2026. The disclosure rulebook is the European Sustainability Reporting Standards (ESRS), drafted by EFRAG and adopted by the European Commission.
Who has to comply with CSRD post-Omnibus I?
Roughly 6,000 of the largest EU undertakings, down from the original ~50,000. The thresholds: EU companies with 1,000+ employees AND €450m+ net turnover. Non-EU parent groups with €450m+ EU turnover, where they have a subsidiary or branch over €200m. Listed SMEs are fully exempt. Wave 1 reporters continue under existing rules through FY2026; first reports under the new framework cover FY2027 (lodged in 2028).
What is ESRS E1-9?
ESRS E1-9 is the Disclosure Requirement under ESRS E1 (Climate Change) covering the anticipated financial effects of material physical and transition climate risks. Companies must quantify the euro impact across short, medium and long-term horizons. It is the hardest single disclosure in the standard, and it was untouched by Omnibus I simplification. Asset-level physical climate risk data, multi-pathway scenarios and a credible translation from hazard exposure to financial effect are all required to answer it.
What changed in Omnibus I?
Omnibus I narrowed CSRD scope from ~50,000 to roughly 6,000 companies, cut mandatory ESRS datapoints by approximately 60%, removed all voluntary datapoints, cancelled the planned sector-specific ESRS, removed the move from limited to reasonable assurance, and dropped the Paris Agreement compatibility wording on transition plans. What it didn't touch: double materiality, the topical climate standard E1, and the E1-9 financial-effects test. The simplification cut content; it didn't cut the climate test.
When do CSRD reports under the new framework start?
First reports under the post-Omnibus framework cover FY2027, lodged in 2028. Wave 1 reporters (the largest companies already reporting) continue under the existing framework for FY2024-2026. Member states have 12 months from Omnibus I entry into force (deadline ~19 March 2027) to transpose the new provisions, and may permissively exempt former Wave 1 companies that fall below the new thresholds for FYs starting between 1 January 2025 and 31 December 2026, country by country.
How does Climate X help with CSRD physical climate risk disclosure?
Climate X provides asset-level physical climate risk data built for CSRD double materiality, ESRS E1-9 anticipated financial effects, and limited assurance from Year 1. The Spectra platform covers 2 billion+ assets globally with 11 hazards, multi-pathway scenarios using CMIP6 SSPs and CMIP5 RCPs across short, medium and long-term horizons aligned to ESRS E1 strategic planning, plus translation of hazard exposure into expected loss in euros. Methodology is ISO 27001 and ISO 14001 certified and defensible to the statutory auditor or independent assurance services provider. Explore Spectra or talk to a climate risk expert about your CSRD roadmap.
From hazard to euros.
Asset-level physical climate risk and adaptation data, ready for CSRD double materiality, E1-9 disclosure and limited assurance from Year 1.
