EFRAG has released the draft N-ESRS. Here is what non-EU companies in CSRD scope need to know.

The Omnibus reform reduced the number of non-EU companies subject to CSRD from roughly 10,000 to approximately 1,200. For those that remain in scope, a dedicated reporting standard is now taking shape. EFRAG released a draft version of the N-ESRS, the European Sustainability Reporting Standards designed specifically for non-EU multinationals, in mid-June 2026. A public consultation is expected to follow in July 2026, with a technical advice deadline in January 2027.

What N-ESRS is and who it applies to

N-ESRS applies to non-EU companies that meet the revised CSRD threshold: more than 1,000 employees and more than €450 million in EU revenue, or more than €200 million generated through a single EU subsidiary. The US has the highest remaining exposure, with an estimated 350 to 450 companies still in scope. UK companies account for roughly 150 to 200, and Switzerland and Japan around 100 to 150 each.

The N-ESRS is not a lighter version of the standard ESRS. It is a tailored version that accounts for the specific position of non-EU groups reporting at a consolidated level, but the core double materiality logic and the fair presentation objective remain in place.

What changed compared to the earlier draft

The June 2026 draft reflects EFRAG’s resumed work on N-ESRS, which was paused during the Omnibus negotiations. The revised draft clarifies the scope of value chain disclosure obligations for non-EU parent companies, adjusts the phasing of certain datapoints, and introduces more explicit guidance on how the standard interfaces with equivalent non-EU reporting frameworks such as ISSB-aligned standards already applicable in some jurisdictions.

What to do if you are in scope

Non-EU companies that remain within the CSRD threshold should treat the consultation period as a working window, not a waiting period. The January 2027 technical advice deadline means that the final N-ESRS will be in place well before Wave 2 reporting obligations begin for FY2027. Starting a gap assessment now, against the draft standard, is a practical use of the consultation timeline.

For companies approaching the threshold, a structured assessment of EU revenue exposure is the first step. The threshold is lower than many non-EU groups expect.

Voluntary use

Non-EU companies that fall below the threshold but face sustainability disclosure requests from EU customers, investors, or financial partners can use the N-ESRS voluntarily. The standard provides a structured framework for responding to those requests in a format that EU counterparties will recognise.

See our CSRD and reporting solutions to understand where you stand!

“The Omnibus changed who has to report. The N-ESRS determines how. For the global companies that remain in scope, this draft is the most important document to engage with right now.”

Jatin Budhraja

Sustainability Advisory Director