CSRD scaled back, audit duty stays: what still applies to your business
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From financial year 2027, far fewer companies will have to report on sustainability. The energy-saving obligations remain, however, and the energy audit gets a new threshold. If you cross the CSRD off your list, you still need to look at your energy use.
The CSRD will only apply to the largest companies
From financial year 2027, only companies with more than 1,000 employees and more than €450 million in net turnover report on sustainability. This follows from Omnibus I, Directive (EU) 2026/470, published in the Official Journal of the EU on 26 February 2026. The first report under the new threshold will appear in 2028. The Netherlands wants to use a member-state option: companies that had to report from financial year 2024 but fall below the threshold from 2027 would then be exempt for 2025 and 2026. That arrangement has not yet been adopted. The Netherlands must transpose the CSRD parts of the directive into national law by 19 March 2027. Companies outside the CSRD may report voluntarily using the VSME. The voluntary EU standard that the European Commission adopted on 3 July 2026 is based on it.
From financial year 2028, a separate rule applies to groups with a parent company outside the EU and the EEA. The European subsidiary or branch must then publish a sustainability report for the whole group if the parent has more than €450 million in net turnover in the EU or EEA and that subsidiary or branch has more than €200 million.
The energy audit will depend on your energy use
Under the revised Energy Efficiency Directive (EED), your energy use determines whether you need an energy audit, no longer your headcount or turnover. If your company, including linked enterprises, uses more than 10 terajoules (TJ) a year on average over the past three years, across all energy carriers, you are subject to the audit obligation. That is roughly 2.8 million kWh. At 85 TJ or more, averaged over the past three years and across all energy carriers, you must introduce an energy management system such as ISO 50001. An energy performance contract or an environmental management system that includes an audit can provide an exemption. Dutch legislation is expected to take effect after the first quarter of 2027. Until then, the current audit obligation applies.
The energy-saving obligation also remains
Alongside the audit, the Dutch energy-saving obligation remains, and it applies per site. If a site uses 50,000 kWh of electricity or 25,000 m³ of natural gas (equivalent) or more a year, you must take every measure that pays for itself within five years. You report on this every four years. A company can therefore have a saving obligation per site and an audit obligation for the company as a whole at the same time. The decision tree below shows which obligations may apply to you.
Decision tree: which reporting and energy-saving obligations apply to you?
| Question | Yes | No |
|---|---|---|
| 1. Does your company (at group level) have more than 1,000 employees and more than €450m net turnover? | CSRD applies; new to the CSRD from financial year 2027 (first report 2028); if you have reported since financial year 2024, that obligation continues | No CSRD obligation; voluntary reporting is possible with the VSME standard |
| 2. Did you have to report from financial year 2024, but fall below the threshold from 2027? | Expected to be exempt for financial years 2025 and 2026 (Dutch member-state option, law not yet adopted) | - |
| 3. Does your company use an average of 85 TJ or more a year (three-year average, all energy carriers)? | Energy management system, for example ISO 50001; proof by 11 October 2027 | Go to question 4 |
| 4. Does your company (incl. linked enterprises) use more than 10 TJ a year on average over 3 years? | EED audit obligation: energy audit every 4 years; newly obliged companies by 1 April 2028 | Once the revised rules apply, no EED audit obligation. Until then the current audit obligation for large enterprises applies. |
| 5. Does a site use 50,000 kWh of electricity or 25,000 m³ of natural gas (equivalent) or more a year? | Energy-saving obligation: measures with a payback time of 5 years or less; report every 4 years | No energy-saving obligation |
The key dates up to 2028
According to RVO, companies that need an energy management system under the revised EED must submit proof of it by 11 October 2027, subject to the final Dutch legislation. Companies using 85 TJ or more must then submit proof of an energy management system, together with a list of cost-effective measures. Companies that become subject to the audit obligation for the first time under the new rules have until 1 April 2028 for their first audit. If you are already subject to the audit obligation, you submit a new report within four years of the previous audit, with an action plan if it falls after the revision. For each measure, that action plan states a description, the expected saving, the year in which you plan to carry it out, why you chose that year, and any conditions or obstacles.
CSRD and EED deadlines, 2026 to 2028
| When | Rule | What happens |
|---|---|---|
| 26 February 2026 | CSRD | Omnibus I (Directive (EU) 2026/470) is published in the Official Journal of the EU. |
| Financial years 2025 and 2026 | CSRD | Planned Dutch exemption (member-state option, law not yet adopted) for companies that fall below the new threshold from 2027. |
| After the first quarter of 2027 (expected) | EED | Dutch legislation for the revised audit obligation takes effect. Until then the current EED audit obligation applies. |
| Financial year 2027 | CSRD | First financial year under the new threshold (more than 1,000 employees and €450m turnover); report in 2028. |
| 11 October 2027 | EED | Proof of an energy management system (85 TJ or more a year) and a list of cost-effective measures. |
| 1 April 2028 | EED | First energy audit for companies that become subject to the audit obligation under the new rules. |
What does this mean for you?
- Check your company against the new CSRD threshold of more than 1,000 employees and €450 million in net turnover.
- Calculate your average annual energy use over the past three years, across all energy carriers and linked enterprises, and compare it with the 10 and 85 TJ limits.
- Above 85 TJ and no energy management system yet? Proof must be submitted by 11 October 2027.
- Becoming subject to the audit obligation for the first time? Plan the audit well before 1 April 2028.
- Check per site whether the energy-saving obligation applies. RVO's Wetchecker energiebesparing can help.
Sources: EUR-Lex (Directive (EU) 2026/470, 26 February 2026), European Commission (voluntary sustainability reporting standard, 3 July 2026), Netherlands Enterprise Agency RVO (CSRD, checked 30 March 2026; revised EED audit obligation, checked 5 October 2026; energy-saving obligation, checked 26 August 2026).
Does this apply to your business?
Our energy specialists are happy to look at what this means for your connections, your contract and your purchasing situation. Without obligation.
