CSRD Reporting Thresholds 2025: Who Must File Sustainability Reports (2026)

The Corporate Sustainability Reporting Directive (CSRD, Directive EU 2022/2464) phases in across four reporting waves between 2024 and 2028. From FY 2025, any EU company with more than 250 employees, €50M turnover, or €25M balance sheet total must publish ESRS-aligned reports. The directive captures approximately 50,000 firms across all 27 member states. The 500-employee threshold under the legacy NFRD dropped to 250, a 4.5x expansion of the in-scope population.

What are the CSRD reporting thresholds at a glance?

CSRD reporting thresholds are the company-size criteria the EU uses to determine which firms must publish ESRS sustainability reports, set by Directive (EU) 2022/2464 with phased application across four reporting waves.

DataDrivenAEC’s analysis of the four phases shows the operational reality: any architecture firm above the 250-employee bar files starting FY 2025, and the ESRS report must include Scope 3 disclosures covering buildings the firm owns or develops. The reporting standard is ESRS (European Sustainability Reporting Standards), adopted as Delegated Regulation (EU) 2023/2772.

Who falls into the FY 2025 reporting wave?

The FY 2025 wave is the second of CSRD’s four phased applications, covering all large undertakings under the size definitions in Directive 2013/34/EU regardless of listing status. A company falls into the wave by exceeding any 2 of 3 thresholds on its balance sheet date: more than 250 employees on average, more than €50 million net turnover, or more than €25 million balance sheet total.

This phase captures privately held large companies alongside listed ones. The population grew from ~11,700 NFRD firms to ~50,000 CSRD firms. Property funds, REITs, and large building owners that previously sat below NFRD’s 500-employee floor now land squarely in scope. Architecture and engineering firms with international operations also clear the bar at far smaller headcounts than the listed-only NFRD captured.

The first FY 2025 reports publish in early 2026 with mandatory limited assurance from FY 2024 onward (ISAE 3000 procedures), upgrading to reasonable assurance by 2028 per Article 34a CSRD.

When are non-EU multinationals captured by Article 40a?

Article 40a is the CSRD provision that extends reporting to non-EU parent companies operating in the EU, captured at FY 2028 (publishing 2029) when EU-source turnover exceeds €150 million at consolidated group level for each of the last 2 consecutive financial years.

Capture also requires at least one of: a large EU subsidiary meeting Phase 2 thresholds, OR an EU branch with more than €40 million net turnover. A US-headquartered REIT or Canadian pension fund with European property holdings is in scope regardless of where the parent is domiciled.

What counts as EU turnover for the €150M trigger:

• Rental income from EU-based properties
• Management fees on EU assets
• Asset sales or disposals of EU properties
• All consolidated revenue from EU-source operations

The threshold tests group-consolidated EU turnover, not entity-level turnover. This is a frequent miscalculation among non-EU multinationals. Article 40a was the most-litigated provision during CSRD negotiations because of its extraterritorial reach.

Why did CSRD drop the 500-employee threshold?

The 500-employee NFRD threshold dropped to 250 under CSRD because the European Commission concluded the original threshold left approximately 75% of EU large-undertaking economic activity unmeasured. The reporting gap prevented sustainable-finance flows from differentiating between firms by climate performance. Banks and investors could not source enough comparable data to allocate capital under the EU Taxonomy.

CSRD also switched from loosely specified non-financial statements to fully standardized ESRS, which are mandatory, comparable, and subject to third-party assurance. The assurance requirement was absent under NFRD and is the critical operational change for property firms: client companies can no longer estimate Scope 3 with generic factors, and architects need verifiable, asset-level data to support client compliance.

Together, the threshold drop and the assurance requirement turn building-level whole-life carbon data into a procurement requirement rather than an optional sustainability credential.

What are the most common CSRD threshold mistakes?

Common CSRD threshold mistakes are the four miscalculations that lead non-compliant firms to discover their obligation only at audit, when the cost of catch-up data collection is highest.

1. Assuming legacy NFRD thresholds still protect the company. The 500-employee bar dropped to 250 in Phase 2 (FY 2025). Many privately held firms above 250 employees but below 500 incorrectly assumed continued exemption.

2. Calculating EU turnover at entity level instead of group-consolidated. Non-EU multinationals must use group EU turnover for the €150M Article 40a trigger. A foreign fund with multiple small EU-source revenue streams may breach the threshold collectively while every individual stream stays well below.

3. Treating EU Taxonomy compliance as separate from CSRD reporting. Taxonomy Article 8 disclosures form part of the CSRD Management Report from FY 2024. Firms that built parallel Taxonomy and CSRD reporting workflows duplicate effort and produce inconsistent figures.

4. Missing the SME deferral option. Listed SMEs may defer FY 2026 reporting to FY 2028 under Article 19a(7), but the deferral requires explicit opt-out. Silence does not defer.

How DataDrivenAEC automates compliance data preparation

ESRS E1 disclosure preparation requires asset-level building data — embodied carbon per material, EPDs, and whole-building LCA modules per EN 15978. Pulling this data from a project at handover takes 2–4 hours of cross-referencing manually. DataDrivenAEC builds custom agents that run this check on your drawing set and deliver the findings as a structured report. See all agents →

Frequently asked questions

Does CSRD apply to my US-headquartered REIT with European properties?

Yes, from FY 2028 (publishing 2029) if the REIT has more than €150 million in EU-source turnover at consolidated group level for two consecutive years AND a qualifying EU subsidiary or branch. EU-source turnover includes rental income, management fees, and asset sales from EU properties. The calculation is at the group level per Article 40a, not per individual entity.

What is the deadline for filing FY 2025 reports?

FY 2025 reports publish in 2026 alongside the financial Management Report, with limited third-party assurance under ISAE 3000 procedures. Deadlines follow national accounting law in each member state. Filing typically falls four to six months after fiscal year end. Verify the exact date with your statutory auditor and local accounting law for jurisdiction-specific requirements.

Can my listed SME defer reporting until FY 2028?

Yes, listed SMEs may opt out of FY 2026 reporting and defer to FY 2028 under Article 19a(7) of CSRD. The deferral requires explicit opt-out. Silence does not defer; document the deferral decision in the Management Report and verify the SME definition under Directive 2013/34/EU thresholds before claiming the exemption.

Are EU subsidiaries exempt if the parent reports under CSRD?

Yes, EU subsidiaries consolidated into a parent’s CSRD report are exempt from separate reporting per Article 19a(9). The parent report must specifically include the subsidiary’s sustainability data, and the subsidiary publishes a reference to the parent report. Subsidiaries of non-EU parents follow Article 40a separately when the parent is not in CSRD scope.