CSRD for insurers after the Omnibus: who reports when (as of June 2026)

Outdated accounts of the CSRD circulate, because much moved in 2025/2026. The precise state as of June 2026: both Omnibus changes are law — the postponement (“stop-the-clock”, Directive (EU) 2025/794, since April 2025) and the scope-narrowing (Directive (EU) 2026/470, adopted 24 February 2026, in force since 18 March 2026). The only piece still open is the revised ESRS draft ^[3][4][2].

This sequence is the most common source of error: anyone still saying “the Omnibus proposal is in trilogue” is on early-2025 footing. The scope-narrowing is no longer a proposal — it is enacted.

The CSRD — Directive (EU) 2022/2464 — is not a free-standing regime; it primarily amends the Accounting Directive 2013/34/EU. Reporting follows the ESRS (European Sustainability Reporting Standards) on double materiality (impact and financial), initially with limited assurance and digital tagging ^[1].

The ESRS sit in Commission Delegated Regulation (EU) 2023/2772 and comprise 12 standards: two cross-cutting (ESRS 1 general requirements, ESRS 2 general disclosures), five environmental (E1 climate change, E2 pollution, E3 water/marine resources, E4 biodiversity, E5 circular economy), four social (S1 own workforce, S2 value-chain workers, S3 affected communities, S4 consumers/end-users) and one governance (G1 business conduct). ESRS 2 is mandatory; the topical standards apply subject to materiality ^[2].

Directive (EU) 2025/794 (adopted 14 April 2025, transposition deadline 31 December 2025) postpones the reporting duty — but not for everyone. Only points (b) and (c) of the phase-in rule were amended: wave 1 (large PIEs > 500 employees) is unchanged and reports for FY2024. Wave 2 (other large undertakings) slips to FY2027, wave 3 (listed SMEs) to FY2028 — each two years later ^[3].

The postponement is therefore staggered: those already reporting under the first wave (many large insurers and banks) remain bound; those in wave 2/3 gain two years — subject to the second, substantive change.

The original Commission proposal (COM(2025) 81) became Directive (EU) 2026/470 — adopted 24 February 2026, in force since 18 March 2026. The core point: the CSRD duty is lifted to undertakings exceeding more than 1,000 employees and more than EUR 450m net turnover. This removes a substantial part of the original waves 2 and 3 from mandatory reporting. The first application of the narrowed regime concerns financial years starting on or after 1 January 2027 ^[4].

Important: 2026/470 is a directive and still requires national transposition (deadline 19 March 2027) — national detail dates may vary. Specific nuances (e.g. value-chain caps, sector standards) should be checked directly against the Official Journal text before any concrete statement ^[4].

The genuinely still-“pending” part is not the scope but the revision of the ESRS themselves. EFRAG delivered technical advice in late 2025; the Commission ran a feedback window on the revised (simplified) ESRS draft until 3 June 2026 and intends to adopt “as soon as possible” afterwards ^[2].

From this follows an important caution: until the delegated act is adopted, Delegated Regulation (EU) 2023/2772 with the 12 standards remains legally applicable. Rebuilding your data architecture on a presumed new ESRS set risks working against a draft that may still change.

Large insurers are within scope as public-interest entities (PIEs) under Art. 2(1) of the Accounting Directive regardless of listing — a large unlisted insurer with > 500 employees and NFRD coverage was in wave 1 (FY2024). Captive (re)insurers and small non-complex institutions sit in wave 3 and may limit their reporting; their definitions cross-refer to Solvency II (Directive 2009/138/EC) ^[5].

Two interfaces are central for insurers. SFDR: insurers as financial market participants (e.g. with unit-linked life products/IBIPs) have parallel SFDR disclosures at entity level (incl. PAI) and product level (Art. 8/9) — the ESRS data points are designed to feed SFDR/PAI reporting and reduce duplication. Solvency II: financial materiality under ESRS overlaps with risk management (ORSA, climate scenarios); that ESRS financial materiality should leverage the Solvency II processes is, however, mainly EIOPA supervisory commentary, not black-letter law — and should be attributed as such ^[5].

In practice, ESRS E1 (climate change) and ESRS S1 (own workforce) are most often assessed as material for insurers, frequently complemented by G1 — but this is an empirical observation, not a legal requirement: materiality is entity-specific under the double-materiality assessment.

The CSRD is currently a moving target: wave 1 reports, waves 2/3 are postponed, the > 1,000 threshold lifts many smaller group subsidiaries out of the duty — while large groups remain in — and the ESRS set is being revised. For insurance groups this means: check per legal entity whether the new threshold bites, which wave applies and which disclosures are actually mandatory.

It is precisely this mobility that makes horizon scanning valuable: monitor the CSRD, the two Omnibus directives, the forthcoming ESRS act and the EFRAG/EIOPA outputs at the source, detect changes and route them to the responsible teams (sustainability, actuarial, disclosure) — before they become a deadline.