In short
- The most expensive CSRD myth is the balance sheet criterion. There isn't one, and EUR 225 million appears nowhere in the directive.
- Deleted obligations are still being sold as upcoming: listed SME reporting, sector standards and reasonable assurance.
- As a supplier you have no CSRD duty at all, and above a certain point you have a statutory right to refuse.
Most of what circulates about CSRD requirements is a description of a version that was repealed. The single most common error is a scope test with three criteria and a balance sheet limb, which would pull in companies that have no duty at all. There is no balance sheet criterion. It is not two of three. Listed SMEs are not in. Reasonable assurance is not coming. Sector standards are not coming. The simplified standards are not law yet. Below, eight claims you will meet, each checked against the enacted text, and what to do differently once you drop them.
Does CSRD require you to meet two of three criteria?
No. That test does not exist in CSRD and never did in this form.
Articles 19a(1) and 29a(1) of the Accounting Directive, as replaced by Directive (EU) 2026/470, reach undertakings that exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year. Two tests, joined by a conjunction, both of which must be exceeded.
The two of three structure belongs to a different provision: the large undertaking definition in Article 3(4) of the same directive, whose balance sheet limb is EUR 25 million. It is used for other purposes in EU accounting law. Splicing it onto the CSRD trigger produces a test no legislature ever enacted.
The figure EUR 225 million, which appears in a lot of published guidance including on our own guide until August 2026, is in Directive (EU) 2026/470 nowhere at all. If you see it, the page has not been checked against the Official Journal.
Does CSRD require a company that exceeds either threshold to report?
No. Exceeding one number is not enough, and this is the error with the largest cost attached because it makes companies start programmes they do not need.
- The company: EUR 2 billion turnover, 600 employees
Common wrong answer: In, it is huge
Correct answer: Out. Fails the headcount test - The company: 4,000 employees, EUR 300 million turnover
Common wrong answer: In, look at the headcount
Correct answer: Out. Fails the turnover test - The company: EUR 400 million turnover, 900 employees, large balance sheet
Common wrong answer: In on the balance sheet
Correct answer: Out. There is no balance sheet criterion - The company: EUR 600 million turnover, 1,200 employees
Common wrong answer: In
Correct answer: In, from financial year 2027
Recital 7 of Directive (EU) 2026/470 describes the population in the same terms the articles do: a net turnover exceeding EUR 450 000 000 and an average of more than 1 000 employees.
Does CSRD require listed SMEs to report?
No, and it does not require them to report later either, which is the version that survives in most timelines.
Listed SMEs were once due to report from financial year 2026, then from financial year 2028 after the stop-the-clock directive moved them. Directive (EU) 2026/470 then deleted the wave outright, along with Article 29c of the Accounting Directive, which was the empowerment for the separate listed-SME standard. Recital 21 states that the directive excludes SMEs whose securities are admitted to trading on a regulated market in the Union from the sustainability reporting regime.
There is nothing left to prepare for. If your broker or your listing adviser has you working towards a 2028 listed SME deadline, that deadline no longer exists in the text.
Does CSRD require you to move to reasonable assurance?
No. This one is worth checking on your own project plan, because budgets have been built on it.
The sustainability statement carries a limited assurance opinion, under Article 34(1), second subparagraph, point (aa) of the Accounting Directive. Directive (EU) 2026/470 removed the empowerment that would have introduced reasonable assurance standards by 1 October 2028, on the stated ground of avoiding an increase in assurance costs. So there is no reasonable assurance requirement and no longer a route to one.
What does exist: harmonised limited assurance standards are due from the Commission by 1 July 2027, moved from 1 October 2026. Until then assurance is performed under national standards.
Does CSRD require you to follow a sector-specific standard?
No. The empowerment to create them was deleted.
Directive (EU) 2026/470 removed the third subparagraph of Article 29b(1) of the Accounting Directive, which was both the power to adopt sector-specific reporting standards and the requirement to deliver a first set by 30 June 2026. Recital 20 explains the reason as avoiding an increase in the number of prescribed datapoints. The Commission may still issue non-binding sector guidance, and no such guidance is promised on a date.
Does CSRD require you to comply with the simplified ESRS?
Not yet, and this is the most current trap because the documents genuinely exist.
The Commission adopted C(2026) 5010, revising and simplifying the standards, and C(2026) 5011, on standards for voluntary use, both on 3 July 2026. On 28 August 2026 both were still in the Parliament and Council scrutiny period, and neither was in force. C(2026) 5010 still contained an unfilled entry-into-force placeholder in its own text.
The standards in force are Delegated Regulation (EU) 2023/2772 as amended by (EU) 2025/1416. Any article describing what the simplified standards require, including the widely quoted reduction in mandatory datapoints, is describing an explanatory memorandum rather than law. Build to the version in force.
Does CSRD require you, as a supplier, to answer your customer?
No. You have no obligation under CSRD unless you are in scope yourself, and if you are reading this as a supplier you almost certainly are not.
What is true is that your customer has an obligation to report value chain information, which is why the questionnaire arrives. Nothing in the directive turns that into a duty on you. The commercial pressure is real, but it is commercial.
Since February 2026 you also have a defence with teeth. If you do not exceed an average of 1,000 employees and you sit in a reporter's value chain, you are a protected undertaking with a statutory right to decline information beyond the voluntary standards where the request is made for CSRD reporting, and any contractual provision to the contrary is not binding. The reporter must also tell you which parts of its request exceed the standard.
The cap does not let you refuse everything, and treating it as a blanket no will lose you an account. It bites only on CSRD reporting requests: due diligence, risk management, tenders and ordinary procurement questions sit outside it, as does anything you have already agreed contractually within the voluntary standard. Where the line falls is what a customer may not ask you.
Does CSRD require you to use VSME?
No, and VSME is not what most people think it is either.
VSME is an EFRAG standard, not a Commission act. Its only standing in EU law today is Commission Recommendation (EU) 2025/1710 of 30 July 2025, which reproduces it and recommends its use. A recommendation binds nobody. Its recital 16 confirms there is no obligation to assure information reported by non-listed SMEs and that a self-declaration is sufficient.
A binding voluntary standard is coming: Article 29ca of the Accounting Directive requires the Commission to establish standards for voluntary use, based on that Recommendation in its original version, and C(2026) 5011 is the act. It was still in scrutiny in August 2026 and is written to apply from financial years beginning on or after 1 January 2027. Until then, treat the VSME standard as the sensible target rather than a legal requirement.
What should you do differently once you drop these?
Three things, and the first one is free.
Rerun the scope test on your own numbers. Turnover above EUR 450 million and headcount above 1,000, both, consolidated if you are a parent. A material number of companies currently running CSRD programmes are out and do not know it.
Stop budgeting for deleted obligations. Sector standards, reasonable assurance and listed SME reporting are three separate line items that can come out of a plan today.
Move the effort to what survived. For companies in scope, that is a greenhouse gas inventory that can withstand a limited assurance opinion. For everyone else, it is a repeatable inventory good enough to answer a customer, which is a much smaller job. A free account gets you a first number without a sales call, and there are 5,000+ users on the platform.
One limitation to know before you rely on the output for an assurance conversation. A Mid-Market reviewer rated us 4 out of 5 on G2 in July 2026 and said the applied conversion factors and distance calculations are not exposed to the user, so they could not always trace how an input became an entry. If your figures are going under an opinion, ask us about that specifically.
Sources: Directive (EU) 2026/470 of 24 February 2026, Directive (EU) 2025/794, Directive (EU) 2022/2464, Directive 2013/34/EU Articles 3(4), 19a, 29a, 29b, 29c, 29ca and 34, Delegated Regulation (EU) 2023/2772, Delegated Regulation (EU) 2025/1416, Commission Recommendation (EU) 2025/1710, Commission acts C(2026) 5010 and C(2026) 5011. Read against the Official Journal text and verified 28 August 2026.
Facts on this page were last verified on 2026-08-28.
