The Corporate Sustainability Reporting Directive (CSRD) is the EU law that requires large companies to publish sustainability information to a common standard. It doesn’t decide whether you may buy carbon credits, but it does decide how in-scope companies report them. Its scope changed sharply in 2026. This page sets out the current position as of October 2026. It is part of our claims and rules section.

Status as of 5 October 2026

The Omnibus I Directive (EU) 2026/470 is in force, and member states must transpose it by 19 March 2027Source 1. The Commission adopted revised ESRS on 3 July 2026; its page listed them as not yet in force when we checkedSource 5. We review this page monthly.

Key dates

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CSRD and ESRS: key dates, as of October 2026
DateWhat happened
16 Dec 2022CSRD, Directive (EU) 2022/2464, published in the Official Journal
31 Jul 2023Commission adopts the first set of ESRS
22 Dec 2023ESRS published as Delegated Regulation (EU) 2023/2772
14 Apr 2025"Stop-the-clock" Directive (EU) 2025/794 delays later reporting waves by two years
24 Feb 2026Omnibus I, Directive (EU) 2026/470, adopted
3 Jul 2026Commission adopts revised ESRS and a voluntary standard
19 Mar 2027Deadline for member states to transpose the Omnibus reporting changes

As of Oct 2026 · Source: [1] Directive (EU) 2026/470 amending the CSRD and CSDDD (Omnibus I)

Dates come from the Official Journal textsSource 4Source 3Source 1 and the Commission’s list of CSRD delegated actsSource 5.

Who has to report now

Omnibus I limits mandatory sustainability reporting to undertakings that exceed a net turnover of €450 million and an average of 1,000 employees during the financial year. The same thresholds apply to groups on a consolidated basis and to listed issuersSource 1. The directive says this excludes smaller companies to focus the burden on the largest undertakings, and that companies below the thresholds can still report voluntarilySource 1.

For non-EU groups, reporting applies where the group generated EU net turnover above €450 million in each of the last two consecutive financial yearsSource 1.

The timing works like this:

  • Companies newly in scope (the second wave) report for financial years starting on or after 1 January 2027, after the stop-the-clock directive moved that date back by two yearsSource 3Source 1.
  • Companies that already reported but fall below the new thresholds can be exempted by member states for financial years starting in 2025 and 2026. They fall outside the directive from financial years starting on or after 1 January 2027Source 1.

Smaller suppliers get protection too. Reporting companies can’t require information beyond a voluntary standard from value-chain undertakings with up to 1,000 employees, and those undertakings can decline such requestsSource 1.

What ESRS E1 asks about carbon credits

The climate standard, ESRS E1, has a dedicated disclosure, E1-7, on greenhouse gas removals and mitigation projects financed through carbon creditsSource 2. For credits from outside the value chain, a company discloses, where applicable:

  1. the total carbon credits, in tonnes of CO₂e, verified against recognised quality standards and cancelled in the reporting period; and
  2. the total credits planned to be cancelled in the future, and whether that rests on existing contractsSource 2.

The standard requires credits to be disclosed separately from greenhouse gas emissions and reduction targets, and its application rules say a company must not present carbon credits as a means to reach its emission reduction targetsSource 2. It says the aim is to show the extent and quality of the credits a company buys from the voluntary market, potentially to support neutrality claimsSource 2. Removals from the company’s own operations and value chain are reported separately from purchased creditsSource 2.

Net-zero targets and neutrality claims

ESRS E1 also sets conditions on two kinds of statement:

  • Net-zero targets. A company that discloses one must explain the scope, methods and frameworks, and how residual emissions, after approximately 90–95% of emission reduction, are to be neutralised, for example by removalsSource 2.
  • Neutrality claims. A company that has made public claims of greenhouse gas neutrality involving carbon credits must explain whether they are backed by reduction targets, whether and how the claims and the reliance on credits neither impede nor reduce the achievement of those targets, and the credibility and integrity of the credits usedSource 2.

These rules come from the first set of ESRS. The revised ESRS adopted on 3 July 2026 amend that regulationSource 5; we will update this section once the revised text is in force.

Reporting is not marketing

CSRD disclosures sit in the management report. Claims to consumers are governed by separate EU consumer law, which bans offset-based claims that a product has a neutral, reduced or positive climate impact from 27 September 2026Source 6. A company can report credits correctly under ESRS and still breach consumer law with its product labels. Our page on the EU green-claims ban covers that side.

Claims: credits in a sustainability statement

  • Report credits as their own line: tonnes cancelled, tonnes planned, quality standardSource 2.
  • Don’t present credits as a way of reaching your emission reduction targets, or mix them into your scope 1, 2 or 3 figuresSource 2.
  • If you claim neutrality, explain how it relates to your reduction targets and the quality of the credits, as E1-7 requiresSource 2.

For how target-setting standards treat credits, read SBTi and carbon credits. For the emissions you report, see scope 1, 2 and 3 explained.