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How Corporate Issuers Should Resume CSRD Readiness in 2026

Insights, Tools and Solutions

As the European Union’s Simplification Omnibus Package enters into force in early 2026, companies can resume preparing for the Corporate Sustainability Reporting Directive (“CSRD”) based on updated exposure thresholds, reporting dates, and disclosure requirements.

The next wave of corporate reporters, large EU and U.S. multinational companies, are mandated to submit compliant reporting in 2028 on FY 2027 data. To meet the new reporting timeline, companies will need to complete double materiality assessments, gap analyses, and implement quantitative data collection mechanisms by the end of 2026. This needs to be completed in alignment with the new European Sustainability Reporting Standards (“ESRS”) and in an auditable manner.

To prepare for CSRD, organizations should strengthen sustainability governance, complete or update double materiality assessments, and build data and control frameworks aligned with ESRS.

Key Challenges for Resuming CSRD Preparedness

Refreshing Prior Efforts & Disclosure Volume: Navigating broad topics and technical reporting requirements while restarting internal momentum.
Global Regulatory Alignment: Streamlining compliance across multiple jurisdictions, minimizing redundancy and ensuring consistency.
Standardized Reporting and Peer Comparability: Preparing disclosures where sustainability information is comparable among competitors.
Assurance & Data Accuracy: Define clear ownership structures to drive accurate, transparent, and auditable data processes that meet assurance requirements.

CSRD Reporting Groups

In-Scope Entities

Reporting Groups	Report Date	Threshold Criteria
NFRD Companies (complete)	2025 on FY24; permission to omit certain disclosures extended to 2028	Large, public-interest entities with >500 employees
Other Large EU Companies & Subsidiaries – including U.S. Multinationals (upcoming)	2028 on FY27	1,000 employees; EU subsidiary or group with €450M in global revenue
Global Reporting for Non-EU Companies – including U.S. Multinationals (upcoming)	2029 on FY28	€450M in EU revenue; single EU entity or branch with €200M in total revenue

How FTI Consulting Supports CSRD Compliance

Understanding that many companies have undertaken CSRD preparedness efforts prior to the Omnibus Package, FTI Consulting has developed a resource-efficient approach to refresh prior analyses in a manner aligned with the new ESRS. See below for FTI Consulting’s solutions and illustrative compliance timeline to guide your organizations next steps:

Organizational Assessments

Entity Scoping Analysis: Perform a comprehensive analysis of business entities to determine exposure, disclosure timing, and reporting strategy, given new exposure thresholds.
Double Materiality Assessment: Complete new or refresh prior DMA to ensure alignment with updated ESRS standards to determine which topics are material and require reporting.
ESRS Gap Analysis & Roadmaps: Identify compliance gaps, based on newly-released ESRS guidance, to map reporting requirements against existing disclosures, documentation, and policies.
EU Taxonomy: Prepare to meet EU Taxonomy requirements through economic eligibility assessments, disclosure preparation, and documentation that meets assurance requirements.

Implementation & Reporting

Sustainability Governance, ICSR and Assurance Preparedness: Design tailored, formalized sustainability governance structures. Develop internal controls to support sustainability data accuracy and assurance readiness.
ESG Software Selection & Implementation: Determine appropriate information systems and implementation approach to meet the needs of your ESG maturity, reporting goals, and unique organizational needs.
Gap Remediation & Implementation: Prioritize metrics for data collection and provide recommendations to close identified gaps, considering resource requirements, timing of data collection, and materiality of specific gaps.
CSRD Report Drafting: Prepare qualitative and quantitative sustainability disclosures aligned with material ESRS topical standards.

Illustrative Timeline Supporting CSRD Compliance Readiness

Download an illustrative CSRD timeline that outlines recommended next steps for companies to resume compliance preparedness here.

Please note that this timeline is provided for general reference only, not compliance advice, and may not reflect all requirements applicable to your organization. We welcome the opportunity for further discussion. Please contact us with any question or comment.