Is my company in scope of CSRD post-Omnibus I?

With Omnibus I (Directive (EU) 2026/470), only companies meeting both cumulative conditions are in scope: more than 1,000 employees AND more than €450 M consolidated net turnover. If even one of the two is not met, the company exits the mandatory CSRD scope. This significantly lightens the burden for European mid-caps. Note: some sector-specific obligations (banking, insurance) remain independent from CSRD thresholds.

What if I only buy a few thousand credits per year?

ESRS E1-7 has no fixed materiality threshold for carbon credits: as soon as a company is in CSRD scope, every acquired and used credit must be documented. For a few thousand credits, the table remains readable and easy to compile. Discipline is less about quantity than about rigour per line. An SME acquiring 500 tCO₂eq/yr across 3 different projects documents all 3 projects per ESRS E1-7.

How do I integrate a soil project covering E1, E3 and E4?

A rigorous regenerative soil project brings value across several ESRS: E1 (carbon sequestration), E3 (water retention, infiltration, runoff), E4 (biodiversity). The practice is to mention the project once in E1-7 (with its carbon figures), then reference the project in E3 and E4 with their specific indicators (litres of water retained per hectare, species abundance). This crosscut is an advantage of soil credits vs DAC or avoidance. Serious ESG leaders make use of it in reporting and communication.

What if a project has no corresponding adjustment?

Disclose it as such in ESRS E1-7. Most current voluntary market credits do not have it, and that is documented. The double-counting risk exists in theory but is limited: NDC states do not count voluntary credits in their inventories, and industry practice corroborates the absence of double-claim. For prudent buyers, favouring credits with corresponding adjustment when possible (Switzerland a pioneer, some African projects since 2024) is a reinforced defensive signal. For European soils, the issue is less sharp thanks to the LULUCF frame.

Must I disclose the price paid per credit?

ESRS E1-7 does not require credit-by-credit unit pricing, but it asks for information about financial commitments linked to credits. Most companies consolidate at portfolio level ('total volume X tCO₂eq, total spend €Y, weighted average price Z €/t'). For ESG analysts and investors, this average-price information helps assess strategic coherence. A very low average price (below 5 €/t) may signal a low-ambition strategy, a high price signals serious investment.

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CSRD & carbon credits: your ESRS E1-7 report

What the CSRD concretely requires about your carbon credit purchases

30-second takeaway

ESRS E1-7 requires reporting each credit separately: volume, type, standard, European share, corresponding adjustment. Omnibus I (Directive 2026/470) raises CSRD thresholds to 1,000 employees AND €450 M, for fiscal years starting 1 January 2027.

CSRD came into force in 2024 for the first concerned companies. With the 2026 Omnibus I revision, its scope is clarified. For carbon credits, ESRS E1-7 imposes detailed reporting that must be anticipated. Here is what to document, how and with which indicators.

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ESRS E1-7: detailed reporting of each acquired and used credit.

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Omnibus I: thresholds raised to 1,000 employees AND €450 M net turnover (Dir. 2026/470).

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Application: fiscal years starting 1 January 2027.

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Key indicator: European share of credits used.

What CSRD is and whom it concerns

The Corporate Sustainability Reporting Directive (CSRD), Directive (EU) 2022/2464, imposes on large European companies an extremely structured sustainability reporting, based on European Sustainability Reporting Standards (ESRS). The first application wave concerned companies already subject to NFRD (>500 employees, >€500 M balance sheet or >€50 M net turnover) for their 2024 fiscal year. The second wave covered other large European companies for 2025. The Omnibus I Directive (Directive (EU) 2026/470, expected to enter into force early 2026) raises the thresholds: only companies with more than 1,000 employees AND more than €450 M consolidated net turnover are now in scope. This raises the bar significantly, but the obligations remain identical for in-scope companies. Application: fiscal years starting 1 January 2027 onwards.

The 12 ESRS and the place of climate (E1)

The CSRD rests on 12 thematic ESRS grouped in four pillars: ESRS 1 and 2 (cross-cutting), ESRS E1 to E5 (environmental), ESRS S1 to S4 (social), ESRS G1 (governance). On the environmental side, ESRS E1 covers climate change, E2 pollution, E3 water and marine resources, E4 biodiversity, E5 circular economy. ESRS E1 has the broadest scope: it covers climate policies, targets, actions, allocated resources, transition KPIs (scope 1, 2, 3 per GHG Protocol, carbon intensity, energy performance) and the financial dimension (transition risks, opportunities). Data point E1-7, of interest here, specifically concerns 'removal and beyond-value-chain mitigation projects, and carbon credit financing'. That is where credit reporting sits.

Data point E1-7: what it asks exactly

ESRS E1-7 requires documenting, for each credit acquired and used during the fiscal year: volume in tCO₂eq, type (nature-based removal, technology removal, avoidance), methodology and standard, project geography (ideally regional, even country level), vintage, possible CCP-approved status, 'corresponding adjustment' status under Paris Agreement Article 6 (signalling that a state has explicitly waived the credit in its national inventory), and European (EU-27) share of the used credit portfolio. Reporting is at credit-level, not just aggregated portfolio level. This granularity requirement is the main specificity of ESRS E1-7 vs prior requirements (NFRD, GRI). It forces tracking discipline from purchase.

The 'European share' indicator is central in ESRS E1-7. The regulation explicitly encourages buyers to favour credits generated on EU territory for several reasons. (1) Coherence with the European climate strategy (LULUCF target -310 Mt CO₂eq/yr by 2030). (2) Reduced regulatory risk: non-EU credits can be affected by host-country regulatory changes (e.g., countries reversing on corresponding adjustment). (3) Audit simplicity: European projects are more accessible to physical verification. (4) Narrative coherence: the company contributes to the territorial ecosystem from which it benefits. For buyers, aiming for a European share above 50 % of the portfolio is a strong defensive signal. French, German, Spanish or Italian soil credits are priority assets for this strategy.

Corresponding adjustment under Article 6

The Paris Agreement (Article 6) provides that when a state sells a carbon credit to a foreign buyer, it must add this credit to its own national emissions inventory (corresponding adjustment) to avoid double counting. Without corresponding adjustment, a credit can be counted twice: once by the state in its NDC commitments, once by the corporate buyer in its reporting. Most current voluntary market credits do not have corresponding adjustment, which is not in itself a problem for CSRD reporting (ESRS E1-7 only asks to disclose the status, not to require it). For European soil credits, the issue often arises less acutely, because they are generated within the EU and their accounting already fits within the consolidated European LULUCF. The upcoming CRCF framework will clarify this point.

The 'non-substitution principle'

A key principle of ESRS E1-7: carbon credits do not substitute for emission reduction. The company must first document its reduction trajectory (typically SBTi 1.5°C-validated), then residual emissions, and only after that mention the credits it uses to contribute beyond its value chain. Presenting credits as a 'solution' to unreduced emissions is explicitly contrary to the standard's spirit and exposes to unfavourable audit. The contribution logic (not offsetting) is central. In practice: do not write 'we have offset X tonnes' but 'we have reduced our emissions by A %, and we have contributed to funding Y climate projects for Z tCO₂eq'. This editorial discipline matters as much as the numerical discipline.

How to structure reporting in practice

ESRS E1-7 reporting typically takes the form of a structured table, integrated in the sustainability report or in annex. Typical columns: credit serial number (or project ID), tCO₂eq volume, type, methodology and version, standard, vintage, geography, CCP status, corresponding adjustment status, unit and total price. At aggregate portfolio level, indicate: total volume acquired during the fiscal year, total volume retired (used for a claim), removal vs avoidance split, European share, CCP-approved share. For structured buyers, building this table from the procurement phase lets documentation accumulate continuously and avoids painful year-end compilation. Many carbon tracking platforms (Persefoni, Sweep, Plan A) now integrate pre-formatted ESRS E1-7 modules.

CSRD audit: what an auditor expects

CSRD reports are audited by a statutory auditor or an accredited Independent Assurance Service Provider (IASP). The assurance level starts at 'limited assurance' and will progressively shift to 'reasonable assurance' (equivalent to financial audit) from 2028. The auditor expects three things on ESRS E1-7. (1) Internal coherence: do declared figures match invoices, standard registries, signed contracts? (2) Traceability: can each declared tonne be traced back to a registry-identified credit? (3) Compliance with the non-substitution principle: is the reduction trajectory clearly separated from carbon contribution? Preparing a complete audit file (invoices + registry extracts + PDD + VVB reports + internal methodological note) secures the process. Many auditors begin reviews with this section because it is concrete and verifiable.

In practice

Start the ESRS E1-7 table from the very first credit purchase, not at year-end. Each row = one credit, completed immediately with all required columns. That discipline is what secures the audit.