Who reports
1,000+ staff and €450M+ turnover
Omnibus I raised both thresholds, and a company now has to cross both. Listed SMEs left the scope entirely.
SourceCSRD / ESRS (2026)
Midgard runs agents that read your invoices, receipts and policies, work out your emissions, and file the disclosures those documents can support. What is left is a short list that genuinely needs a person.
No account needed. The demo opens straight into a filled-in dashboard.
Where the rules stand
Directive (EU) 2026/470 was published on 26 February 2026 and has been in force since 18 March. Every figure below links to the document it came from, so you can check the page rather than trust it.
Who reports
1,000+ staff and €450M+ turnover
Omnibus I raised both thresholds, and a company now has to cross both. Listed SMEs left the scope entirely.
SourceChange in scope
~90% fewer companies
The Council put the reduction at around 90% for the CSRD and around 70% for the due diligence directive.
SourceIn force since
18 March 2026
Published in the Official Journal on 26 February 2026. Member States transpose the CSRD provisions by 19 March 2027.
SourceStandards
ESRS (2026), 61% fewer mandatory datapoints
Adopted 3 July 2026 and not yet in force: the act cannot take effect until four months after adoption, and applies to financial years beginning on or after 1 January 2027. Reporters may adopt it early for FY2026.
SourceAssurance
Limited, and staying limited
The planned escalation to reasonable assurance was removed rather than postponed.
SourceDouble materiality
Unchanged
Simplification did not touch the principle. The four-step assessment remains the foundation of what you report.
Source| Cohort | Who it covers | Financial year | First report |
|---|---|---|---|
| Wave 1 | Large listed companies already reporting under the NFRD | FY2024 | Filed 2025, then exempt for FY2025 and FY2026 if now under the thresholds |
| Wave 2 | Large companies over both new thresholds | FY2027 | 2028 |
| Listed SMEs | Small and medium listed companies | Not applicable | Removed from scope |
| Non-EU groups | €450M+ EU turnover with a large EU branch or subsidiary | FY2028 | 2029 |
Sources last checked . Scope and timing depend on your own figures and your Member State’s transposition.
Sustainability reporting is mostly clerical: finding the document, reading a number off it, and proving where the number came from. That is the part the agents take.
Gmail and Outlook, plus the utility, waste and travel invoices your suppliers send. You re-key none of it.
Kilowatt-hours off an energy bill, tonnes off a waste invoice, distances off an itinerary, spend off a purchase order.
Emissions across Scope 1, 2 and 3, categorised against the GHG Protocol and ISO 14064, with the source document attached.
Midgard files the disclosures your documents can back. Everything else becomes a task naming the datapoint it belongs to.
ESRS 1 and ESRS 2 apply to every reporter. The ten topical standards apply where your double materiality assessment says they do, and that assessment came through the simplification unchanged.
Each figure keeps a link to the invoice or receipt it was read from. When an assurance provider asks where a number came from, you open the document instead of going looking for it.
Policies get the same treatment. Upload one and the agent checks it against what the standard expects, names the clauses that are missing, and drafts replacement wording you can edit and export.
The demo opens as a fictional Amsterdam design studio in its second year of measuring, with four years of emissions, a policy library, and a task list of gaps the agents raised. A company that size sits under the CSRD thresholds and would answer a customer through the voluntary SME standard, but the machinery on screen is what a filer uses. All of the data is invented, and nothing you click sends an email or charges a card.
Questions
EU companies with more than 1,000 employees on average and more than €450 million in net turnover. A company has to cross both thresholds, and that single change took roughly 90% of the previously in-scope population back out.
Non-EU groups are caught at €450 million of EU turnover if they also have an EU subsidiary or branch above €200 million. Listed SMEs, which used to be a separate wave, are no longer in scope at all.
SourceDirective (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026Council of the EU press release, 24 February 2026
Wave 2 covers companies over both thresholds that were not already reporting. Their first report covers FY2027 and is published in 2028.
Non-EU groups start a year later, covering FY2028 in 2029. Member States have until 19 March 2027 to write the CSRD changes into national law, so what actually binds you is your own country’s version.
SourceDirective (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026
Only if you are still over the new thresholds. Omnibus I gives wave 1 companies that fall out of scope a transition exemption covering FY2025 and FY2026, so a company that reported once may have nothing further to file.
Plenty of wave 1 filers stay in scope and simply continue. Working out which group you are in is arithmetic: headcount and turnover against 1,000 and €450 million.
SourceDirective (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026
The Commission adopted the simplified standards on 3 July 2026, built on EFRAG’s technical advice of 23 December 2025. The act cuts mandatory datapoints by 61% and removes every voluntary one.
The act is adopted but not yet in force. It cannot take effect until four months after adoption, and it applies to financial years beginning on or after 1 January 2027. Companies already reporting may adopt it early for FY2026.
The structure held: twelve standards, two cross-cutting and ten topical. E3 lost its old name, Water and marine resources, and is now just Water. Sector-specific standards were still being drafted and have been dropped.
SourceCommission Delegated Regulation C(2026) 5010 final: the simplified ESRS, adopted 3 July 2026C(2026) 5010 final, Annexes I and II: the twelve ESRS (2026) in full
Yes, and it was never really in doubt during the negotiations. Simplification reduced how much you disclose, not how you decide what to disclose.
The four-step assessment still determines which of the ten topical standards apply to you. ESRS 1 and ESRS 2 apply regardless.
SourceEFRAG technical advice on the simplified ESRSCommission Delegated Regulation C(2026) 5010 final: the simplified ESRS, adopted 3 July 2026
Limited assurance, from your first reporting year. The CSRD originally set out a path to reasonable assurance later on; Omnibus I removed that path rather than delaying it.
In practice that keeps the audit conversation on whether your numbers are traceable rather than whether they can be reperformed. Knowing which document a figure came from does more for you than a tidier spreadsheet.
SourceDirective (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026
Not much more than the voluntary standard covers. Omnibus I caps what an in-scope filer is entitled to require from a value-chain partner that does not exceed an average of 1,000 employees, and the Commission fixed that ceiling by adopting the voluntary standard itself on 3 July 2026.
There are two limits on the limit. The cap bites only on information gathered for CSRD reporting, so a request made for some other reason falls outside it. And it stops a customer compelling you, not asking you: you can still share more voluntarily if that suits the relationship.
Within those bounds it is the provision a supplier should know. It sits in the directive text rather than in guidance, so you can raise it directly with a customer.
SourceDirective (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026Commission Delegated Regulation C(2026) 5011 final: the voluntary standard and the value chain cap
No. Work on them was discontinued as part of the simplification package, so the twelve cross-sector standards are what you report against.
SourceCommission Delegated Regulation C(2026) 5010 final: the simplified ESRS, adopted 3 July 2026EFRAG technical advice on the simplified ESRS
It reads the activity data off your source documents: kilowatt-hours from an energy bill, tonnes from a waste invoice, distance from an itinerary, spend from a purchase order. Published emission factors then turn those readings into Scope 1, 2 and 3 figures, categorised against the GHG Protocol and ISO 14064.
Every figure keeps a link back to the document it came from. Under limited assurance the question you get asked over and over is where a number came from, and that link is what answers it.
SourceGHG Protocol Corporate Accounting and Reporting Standard
Not today. What is published here is a working demo running on invented data, with no live backend behind it. Nothing you click in it sends an email, contacts a supplier, or charges a card.
It is a genuine build rather than a set of screenshots, so the navigation, the disclosure register and the task list all behave the way they did in the product. If that is useful to you, the form below reaches a person.
We keep it in a private object store, out of the object’s path and out of every URL, and we use it to reply to you. There is no newsletter and no analytics profile built against it, and we do not pass it to anyone else.
No. It is a plain-language summary written on 22 August 2026, with each claim linked to the document it came from. That is enough to orient yourself and not enough to decide anything.
Scope, timing and transposition all turn on facts specific to your company and country. Read the directive, or ask someone whose professional indemnity insurance covers the answer.
SourceDirective (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026Directive (EU) 2022/2464 (CSRD)
Answers reflect the rules as they stood on 22 August 2026. This is a summary, not advice.
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