CSRD for Non-EU Companies
Non-EU companies with €450M+ EU net turnover are in CSRD Wave 4 scope. First reports cover FY2028, published in 2029. The threshold was raised from €150M under the Omnibus package. Here is everything non-EU companies need to know.
Non-EU companies with €450M+ EU net turnover are in CSRD Wave 4 scope. CSRD Wave 4 applies to non-EU companies that generate more than €450M net turnover in the EU in each of the two consecutive financial years, AND have at least one EU subsidiary that is a large company or listed SME, OR an EU branch generating more than €22.
Does CSRD apply to your non-EU company?
CSRD Wave 4 applies to non-EU companies that generate more than €450M net turnover in the EU in each of the two consecutive financial years, AND have at least one EU subsidiary that is a large company or listed SME, OR an EU branch generating more than €22.5M net turnover.
The EU turnover calculation is complex for multi-entity groups — it includes revenue from sales to EU customers regardless of where the goods are produced or shipped from.
US companies with significant EU operations are the most commonly affected group. A €450M EU revenue threshold captures many mid-to-large American corporations with European business.
NESRS — the non-EU group standards
EFRAG is developing separate standards for non-EU companies — NESRS (Non-EU Entity Sustainability Reporting Standards). These are expected to be equivalent to ESRS but adapted for the different context of non-EU parent companies reporting on their EU activities.
Until NESRS are finalised, non-EU companies should plan around the full ESRS as the likely baseline. NESRS may reduce the reporting burden for non-EU activities and focus disclosure on EU-specific impacts.
NESRS are expected to be published in final form during 2026 — monitor EFRAG announcements.
Strategic considerations for non-EU companies
Start now even though the deadline is 2029. Building ESRS-compatible data infrastructure takes 18–24 months. Companies that start in 2027 will face the same compressed timeline problem as Wave 2 companies who delayed.
Assign a CSRD owner in your EU operations. Typically this sits with the CFO of the EU subsidiary or a dedicated Sustainability function.
Engage your EU auditors early. Your EU statutory auditor is best placed to understand local regulatory requirements and provide CSRD assurance.
Consider voluntary early reporting. Some US companies are voluntarily publishing CSRD-aligned reports ahead of the Wave 4 deadline to demonstrate ESG leadership to EU investors and customers.
Frequently asked questions
Does CSRD apply to US companies listed on EU markets?
EU-listed securities are already covered under existing NFRD rules. Under CSRD, US companies with EU-listed securities and significant EU operations may be caught by Wave 1 or Wave 4 depending on their structure.
Can we use our existing SEC ESG disclosures for CSRD?
Partially. SEC climate disclosure rules (when finalised) overlap with ESRS E1 approximately 40%. CSRD/ESRS is significantly more comprehensive — particularly on social topics, biodiversity, and double materiality. Expect substantial additional work.
Does CSRD apply to our EU joint ventures?
CSRD applies at the company level. EU subsidiaries that independently meet the thresholds must report in their own right. Your parent company's Wave 4 obligation covers the consolidated group view — work with your legal team to map which entities fall in scope.