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Commentary from IntelliTick

The EU cut CSRD's reach by almost 90%. What it means for Indian exporters

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In short

After the Omnibus, EFRAG estimates about 1,200 non-EU companies remain in CSRD's scope, down from about 10,000. Most Indian groups will fall below the new thresholds.

The EU's Omnibus simplification has raised the bar for non-EU groups under the Corporate Sustainability Reporting Directive (CSRD).

The new thresholds

A non-EU group now falls in scope only if it has:

  • EU net revenue above €450 million for two consecutive years, and
  • an EU subsidiary or branch with revenue above €200 million.

Before the Omnibus, the thresholds were €150 million and €40 million. EFRAG, which writes the EU's sustainability reporting standards, estimates this cuts the number of non-EU companies in scope from about 10,000 to about 1,200 — a fall of roughly 88%.

The timetable for those still in scope

  • Reporting under the non-EU standard is due to begin in 2029, for the 2028 financial year.
  • EFRAG's draft non-EU standard (ESRS-40a) was open for public consultation until 31 October 2026.
  • EFRAG plans to finalise its advice in January 2027. The European Commission then holds its own consultation before adopting the standard.

What it means for Indian exporters

EFRAG's estimate breaks the remaining companies down for the US, UK, Switzerland and Japan, but not for India. With the new thresholds, most Indian groups selling into Europe will sit below them and will not report under CSRD themselves.

That is different from being free of European sustainability questions. Companies that still report under CSRD cover material impacts in their value chain, and European buyers already ask suppliers for emissions and other ESG data. Indian exporters that produce their BRSR figures with evidence behind them are in a better position to answer those requests quickly.

Our framework mapping explorer shows where a BRSR Core figure is also asked for in ESRS, GRI, IFRS S2, CDP and SASB.

References

  1. Omnibus Cuts Non-EU Companies in the Scope of CSRD from 10,000 to 1,200: EFRAG — ESG Today. 10 June 2026
  2. EFRAG Releases Proposed CSRD Sustainability Reporting Standards for Non-EU Companies — ESG Today. 27 July 2026

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