CSRD Readiness Checklist for UK Companies

Omnibus I Update (March 2026): This checklist reflects the restructured CSRD: thresholds raised to 1,000+ employees AND €450m+ turnover, simplified ESRS (60%+ fewer data points), VSME value chain cap, and third-country threshold raised to €450m.

1. Scope Assessment (Post-Omnibus I)

1.1 Confirm whether your EU subsidiaries meet revised thresholds

Post-Omnibus I, CSRD applies to EU subsidiaries with 1,000+ employees AND €450m+ turnover (previously 250/€50m). Confirm each EU subsidiary against the new thresholds.

Omnibus I Directive · Published OJ 26 Feb 2026, in force 18 Mar 2026

1.2 Assess third-country parent obligations

UK parent companies with €450m+ EU net turnover (raised from €150m) and at least one EU subsidiary/branch generating €200m+ will need group-level sustainability reporting under ESRS or equivalent.

2. Double Materiality

2.1 Double materiality assessment conducted

Assessed sustainability topics from both impact materiality (effects on people/environment) and financial materiality (risks/opportunities for the company). Results determine which of the 12 simplified ESRS are applicable.

ESRS 1 Para 21-33 · EFRAG IG 1 Double Materiality

2.2 Stakeholder engagement documented

Stakeholder engagement process designed and conducted to inform impact materiality. Documentation includes stakeholder identification, engagement methodology, and how input was incorporated.

3. Simplified ESRS Data Architecture

3.1 Material ESRS standards identified

Based on double materiality results, identified which of the 12 simplified ESRS standards apply. Data points mapped (~400 under simplified ESRS, down from 1,000+ pre-Omnibus).

Simplified ESRS Delegated Act · Adopted 3 Jul 2026

3.2 Data collection processes established

Data collection processes designed for each material data point. Source data, calculation methodologies, and assumptions documented. Internal controls analogous to financial reporting established.

4. GHG Emissions & Climate

4.1 Scope 1 & 2 GHG inventory complete

GHG Protocol-compliant inventory for direct (Scope 1) and purchased energy (Scope 2) emissions. Boundaries, factors, and methodology documented for assurance readiness.

4.2 Scope 3 estimation initiated

Material Scope 3 categories identified. Estimation commenced using available data. VSME cap applies: value chain partners with <1,000 employees can only be asked for VSME-level data (~140 data points).

5. EU Taxonomy

5.1 Taxonomy eligibility screening complete

Economic activities screened against EU Taxonomy technical screening criteria for 6 environmental objectives. Taxonomy-eligible activities identified. Revenue, CapEx, and OpEx allocated.

5.2 DNSH & minimum safeguards assessed

Do No Significant Harm assessments completed for each objective. Minimum safeguards (OECD Guidelines, UN Guiding Principles, ILO) evaluated. Taxonomy-aligned proportions calculated.

6. Governance & Assurance Readiness

6.1 Board oversight structure documented

Sustainability oversight responsibility assigned to board committee or full board. Terms of reference include CSRD compliance. Management accountability documented.

6.2 Evidence architecture designed for assurance

Data trails, source documentation, and internal controls structured for limited assurance scrutiny. Pre-assurance readiness walk-through conducted. Assurance provider identified.

CSRD requires limited assurance from Wave 1 (FY2024). Assurance must be by accredited provider.

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