EU · last verified 2026-09-14
CSRD does not require every EU company to log CO2
Omnibus I, in force 18 March 2026, cut mandatory sustainability reporting to the largest groups. The companies that remain in scope still keep a serious GHG log.
Who is in
An EU undertaking is in mandatory CSRD scope only if it exceeds both more than 1,000 employees and more than EUR 450 million net turnover. That replaced the old “two of three” large-undertaking test (250 employees / €50m / €25m balance sheet). Listed SMEs are out.
Non-EU parents are on a separate route: more than EUR 450 million net turnover generated in the EU in each of the last two years, and a qualifying EU subsidiary or a branch above EUR 200 million.
Newly in-scope EU firms generally first report for FY 2027 (published 2028). Wave-one reporters that stay above the new thresholds continue. Member-state transposition can still move edges.
What they log
ESRS E1 still wants a gross inventory: Scope 1, Scope 2 on both location- and market-based methods, and material Scope 3, in tonnes of CO2 equivalent. Credits and removals are disclosed separately. They are not netted against the inventory to look like a reduction.
The practical log is the working papers behind that disclosure: activity data, factor versions, organisational boundary, and an audit trail. That is what “CO2 log” means here — not a badge.
Who they may not interrogate
Omnibus I added a statutory value-chain cap. Reporting companies must not require “protected undertakings” (up to 1,000 employees) to provide more sustainability information than the voluntary SME standard allows. Those suppliers have a right to refuse extra requests. Estimates fill the gap for the reporter.