CSRD after Omnibus: who's concerned, and when

You're listed on an EU-regulated market with more than 500 employees: you fall under "wave 1" (large public-interest entity, inherited from the former NFRD), already subject since fiscal year 2024, independent of the new Omnibus thresholds. This obligation will end once the French transposition of the threshold increase takes effect (by 19/03/2027 at the latest), unless you then cross the wave 2 threshold.

Cumulative thresholds: more than 1,000 employees AND more than €450M in net revenue. ESRS sustainability report for fiscal year 2027, published in 2028.

Failing to appoint a statutory auditor or an independent third party to certify this information is punishable in France by a €30,000 fine and up to 2 years' imprisonment.

Falling outside the mandatory scope (Omnibus thresholds not reached)? Your clients subject to CSRD will still ask you for ESG data. The voluntary VSME standard becomes the common reference, and the "value chain cap" limits what they can demand from you.