CSRD DIRECTIVE 2026/470 · CLIMATE REVISED ESRS ADOPTED

Physical climate risk data,
ready for CSRD.

The directive shrank. The climate test didn't. After Omnibus I (Directive (EU) 2026/470), CSRD applies only to companies with 1,000+ employees and €450m+ turnover, and the revised ESRS adopted on 3 July 2026 cut mandatory datapoints by roughly 60%. Double materiality survived, climate survived, and the anticipated financial effects disclosure survived with a new number: E1-9 under Set 1, E1-11 once the revised standards apply from FY2027.

From NFRD to the revised ESRS: Source: European Commission, EUR-Lex, EFRAG
Oct 2014 NFRD adopted
Dec 2022 CSRD adopted (2022/2464)
2025 Wave 1 first reports
Apr 2025 Stop-the-Clock Directive
Feb 2026 Omnibus I adopted (2026/470)
Jul 2026 Revised ESRS adopted
Now In scrutiny; entry into force expected Nov 2026
FY2027 First reports under the revised ESRS
In one line

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. The revised ESRS were adopted on 3 July 2026 and apply from financial years beginning on or after 1 January 2027, with early application permitted for FY2026. Double materiality, the climate standard E1 and the anticipated financial effects test all survived the simplification.

Who it applies to

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 revised framework cover FY2027, lodged in 2028, and non-EU ultimate parents follow a year later with FY2028. Wave 1 reporters continue under Set 1 through FY2026, with the option to early-adopt the revised standards or to stay on Set 1 while taking selected reliefs.

The Directive

CSRD is the law. ESRS is the rulebook.

CSRD requires sustainability disclosure under EU law. ESRS specifies what to disclose. Both got simplified in 2026: Omnibus I narrowed scope in February from ~50,000 companies to roughly 6,000 of the largest, and the revised ESRS adopted in July cut mandatory datapoints by roughly 60%. The hard core stayed.

1
Original adoption
CSRD adopted December 2022 as Directive (EU) 2022/2464, replacing the NFRD which had captured ~11,000 companies
2
Current law
Amended by Omnibus I (Directive (EU) 2026/470), in force since 18 March 2026. Member states transpose by 19 March 2027
3
New scope
EU companies with 1,000+ employees AND €450m+ turnover. Listed SMEs fully exempt. Sector-specific ESRS cancelled.
!
Where we are now
Revised ESRS adopted 3 July 2026, in scrutiny, entry into force expected November 2026. First reports FY2027
What survived simplification

60% fewer datapoints. The hard ones stayed.

The revised ESRS adopted on 3 July 2026 cut mandatory datapoints by roughly 60%, close to 70% once voluntary datapoints are counted, killed sector-specific standards, removed the move to reasonable assurance, and dropped the Paris Agreement compatibility wording on transition plans. What it did not cut: double materiality, the climate standard, the anticipated financial effects test, and the asset-level data all three depend on.

01
Double materiality survived

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.

02
The climate test stayed hard

Renumbered, not relaxed.

The revised standards slim narrative content and remove voluntary datapoints. They do not remove the anticipated financial effects of physical and transition climate risk: that disclosure moves from E1-9 to E1-11, and scenario analysis and resilience become standalone requirements at E1-2 and E1-3. Quantified euros, by horizon, by material asset, plus the share of exposed assets your adaptation actions actually cover.

03
One directive, 27 transpositions

Local laws, not EU law direct.

Directives bind member states to a result, not a method. Each EU country transposes CSRD into national law by 19 March 2027, with local variations on lodgement, supervisor and penalties. Multinationals win when the data spine carries every transposition.

The Framework

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.

  • 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 transpose Omnibus I by 19 March 2027
    • Revised ESRS delegated act adopted 3 July 2026, applying from FY2027
  • 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
  • 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)
    • The revised ESRS streamline the methodology; the dual lens stays
  • Chapter 4: ESRS connection

    CSRD says report. ESRS says exactly what.

    CSRD is the legal obligation. ESRS specifies the content. The revised standards were adopted on 3 July 2026 and apply from FY2027, with early application permitted for FY2026. They keep the structure and the hard climate disclosures, and they renumber them.

    • ESRS 1, ESRS 2 cross-cutting; E1-E5 environmental; S1-S4 social; G1 governance
    • Mandatory datapoints reduced by approximately 60%, closer to 70% counting voluntary ones
    • Sector-specific ESRS cancelled by Omnibus I, replaced by possible Commission guidance
    • E1 climate retained, with scenario analysis and resilience promoted to standalone requirements at E1-2 and E1-3
    • Anticipated financial effects renumbered from E1-9 to E1-11, with the physical risk datapoints intact
  • 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
    • Harmonised assurance standards due from the Commission by 1 July 2027
  • 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
  • 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 Omnibus I transposition deadline is 19 March 2027.

    • Member states transpose Omnibus I by 19 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 Data Challenge

The simplification cut content. Not the climate test.

The revised standards trimmed narrative and voluntary datapoints. The asset-level climate data underpinning double materiality, scenario analysis and anticipated financial effects did not move. If you are still in scope, the data problem is the one you already had, with a new disclosure number on it.

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. The revised standard moved asset location disclosure into application guidance, which changes what you print, not what you need to compute: country averages still don't survive limited assurance, and they don't underwrite a credible adaptation plan.

E1-11 anticipated financial effects

Quantified euro impact from material physical and transition climate risks by short, medium and long-term horizon, the carrying amount of assets at material physical risk, and the share of that carrying amount your adaptation actions cover. Formerly E1-9, renumbered to E1-11 in the revised standards, and no easier for the change.

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.

Adaptation coverage, evidenced

E1-11 asks what share of your materially exposed assets is addressed by adaptation actions. That is a number you can only produce if you know which assets are exposed, which measures are in place or planned, and what each one costs and avoids.

Climate X for CSRD

Physical climate risk data, built for CSRD double materiality, E1-9 and E1-11.

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 for E1-2, resilience analysis for E1-3, and the hazard-to-euros translation E1-11 asks for, all from one data spine.

Asset-level exposure, 2bn+ assets

Material physical climate risk for every asset in scope. 12 hazards, building-level vulnerability, geolocation precision down to address and parcel. The granularity double materiality, E1-2 and E1-11 demand, without country averages.

Multi-pathway scenarios for E1-2

CMIP6 SSPs and CMIP5 RCPs covering low-warming and high-warming pathways, with NGFS scenarios for the financial sector view. Short, medium and long-term horizons aligned to ESRS E1 strategic planning, with the scenario rationale documented for the standalone scenario analysis requirement.

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 E1-11 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, CSDS and UK SRS filings.

Adaptation actions, costed

E1-11 asks for the share of materially exposed assets covered by adaptation actions, and E1-3 asks whether the business is resilient. Adapt quantifies defence and retrofit options asset by asset, with capex, avoided loss and payback, so the coverage percentage and the resilience narrative rest on measures you can evidence rather than intentions.

60-second check

Are you ready for CSRD physical climate risk disclosure?

Pick your industry. The financial-effects question tailors itself to where climate risk hits your sector hardest under the anticipated financial effects disclosure (E1-9 under Set 1, E1-11 once the revised standards apply).

CSRD readiness self-check

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Select your industry to tailor the E1-11 financial-effects question (E1-9 under Set 1) to your sector's specific exposure profile.
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Frequently asked

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, and why is it now E1-11?

It is the disclosure requirement under ESRS E1 covering the anticipated financial effects of material physical and transition climate risks: the quantified euro impact across short, medium and long-term horizons, the carrying amount of assets at material physical risk, and the share of that carrying amount addressed by adaptation actions. It is the hardest single disclosure in the standard. Under Set 1 it is E1-9. In the revised ESRS adopted on 3 July 2026 the requirements were renumbered and it becomes E1-11, while E1-9 now covers greenhouse gas removals and carbon credits. Same disclosure, new number, and one worth getting right in your workpapers before FY2027.

Does the simplification change what physical risk data we need?

Not in substance. The revised standards cut narrative and voluntary content, and they moved asset location disclosure from the requirement text into application guidance, so less of the underlying detail is printed. The numbers you print still have to be computed from the same place: which assets are exposed, to which hazards, under which scenarios, over which horizons, and what your adaptation actions cover. Scenario analysis and resilience becoming standalone requirements at E1-2 and E1-3 arguably raises the bar, because both now have to stand on their own rather than sit inside a longer climate narrative.

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 anticipated financial effects test (E1-9 under Set 1, E1-11 once the revised standards apply). The simplification cut content; it didn't cut the climate test. The simplification itself arrived later: the Commission adopted the revised ESRS delegated act on 3 July 2026, applying from FY2027 with early application permitted for FY2026.

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 transpose by 19 March 2027, 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. The revised ESRS themselves apply to financial years beginning on or after 1 January 2027, with early application permitted for FY2026 and a third option to stay on Set 1 while taking selected reliefs.

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 anticipated financial effects (E1-9, renumbered E1-11 from FY2027), and limited assurance from Year 1. The Spectra platform covers 2 billion+ assets globally with 12 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. Adapt then quantifies defence and retrofit options asset by asset, with capex, avoided loss and payback, so the share of exposed assets covered by adaptation actions rests on measures you can evidence. 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 and E1-11 disclosure, and limited assurance from Year 1.

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