CSRD reporting delays as strategic opportunities: Leveraging the breathing space in Nordic real estate.

If you've been waiting to find out how much longer you've got before CSRD reporting starts, the waiting is over – and the question has changed. For most Nordic real estate companies, the answer isn't "2028". It's "you don't have to".

When we originally wrote this post, it was to tell you that you had two extra years. That was true when we wrote it, but it's not anymore.

What actually happened?

Three things, in about eighteen months.

Only the last one really matters now. Stop-the-clock moved the deadlines. Omnibus I removed the thing the deadlines applied to. The wave system is gone. There's no wave 2, no wave 3, and no phased rollout to plan around. There's one test, and you either meet it or you don't. For once, it's nice and simple!

The test

To be in scope now, an EU company has to exceed both of these:

• More than 1,000 employees, and
• More than €450 million in net turnover

Both. Not two out of three, and not one or the other. Being listed on an EU exchange is no longer a trigger on its own – a listed company below those thresholds is out, and listed SMEs have been removed from scope completely.

That "and" is why this matters so much for property. Real estate is capital-heavy and headcount-light. You can hold billions in assets with two hundred people. A company can clear the turnover limb comfortably and still be nowhere near 1,000 employees – which means a lot of Nordic property owners who spent two years preparing for CSRD are no longer required to file anything under it. Our scope explainer goes through the categories in full.

Not all of them. Vertically integrated groups with in-house facilities management, construction or service arms employ more than a thousand people, and some Nordic groups will still be in. Count the heads before you conclude anything.

If you're out

Companies that started reporting for the 2024 financial year and now fall below the thresholds can be let off for the interim years – but only if their member state chooses to allow it. Denmark chose quickly. A ministerial order in force from 26 February 2026 exempts those companies for financial years 2025 and 2026.

Denmark hasn't finished the job, though. The bill implementing the rest is expected in Folketinget this autumn, with the new thresholds – more than 1,000 employees and more than DKK 3,530 million in net turnover – applying from the 2027 financial year. Until it passes, the Danish detail isn't settled, and anyone telling you otherwise is reading a draft.

If you're still in

Four things changed for you, and three of them are lighter than before.

• ‍Assurance stays at limited. The plan to move everyone to reasonable assurance has been dropped, and the deadline for adopting limited assurance standards has moved to July 2027
• ‍Sector-specific standards are gone. The Commission can no longer adopt binding standards for individual sectors – real estate included – and will issue non-binding guidance instead
• ‍The standards themselves are being cut. The revised ESRS reduce mandatory data points by more than 60%, and total data points by more than 70%. They were adopted in July 2026, published in the Official Journal in September, and come into force on 10 November. They apply from the 2027 financial year, with early application possible for 2026 – our ESRS guide covers what the standards actually ask for
• ‍There's now a limit on what you can ask your suppliers. Companies in scope can't require sustainability information from businesses under 1,000 employees beyond what the voluntary SME standard covers. If you've been building a tenant data request on the assumption that you can ask for whatever you need, that assumption has a ceiling now

What didn't change

The reporting duty got smaller. But the data question didn't.

If you're out of CSRD scope, you're still inside somebody else's value chain. Your tenants get asked about the energy their space uses. Your lenders get asked about the energy performance of the collateral – which is your building. And the EPBD sets minimum energy performance standards on individual buildings: the worst-performing 16% of non-residential floor area dealt with by 2030, and 26% by 2033. That survived the Omnibus untouched, and it doesn't care how many people you employ. What makes a building high-risk sets out the rest of the exposure.

So here's the honest position. Nobody is going to fine you for not filing a report you're no longer required to file. But the questions about what your buildings actually use are coming from more directions than they were two years ago – and now they're coming from people who can price the answer.

FAQs

Is CSRD cancelled?

No. It still exists; it still asks for the same kind of report, and companies in scope still have to file one. What changed is who counts as in scope – Omnibus I raised the bar to more than 1,000 employees and more than €450 million in net turnover, and most companies sit below it.

Is CSRD still delayed?

The two-year delay from April 2025 has been overtaken. It moved deadlines for companies that hadn't started reporting, and then Omnibus I removed the phased rollout those deadlines belonged to. If you're in scope now, your first reporting year is 2027, and the report is published in 2028. There's no further delay to wait for.

Do I still have to report under CSRD?

Only if you exceed both thresholds – more than 1,000 employees and more than €450 million in net turnover, in the same company or group. Clear one and not the other, and you're out. Being listed on an EU exchange doesn't change the answer.

I reported for the 2024 financial year. What about 2025 and 2026?

If you still meet the new thresholds, you carry on. If you don't, your member state can exempt you for those two years, and Denmark has. Danish companies caught by that order fall back to the older samfundsansvar statement in the meantime – though the bill now heading for Folketinget proposes removing that requirement too, from the 2026 financial year.

Are listed SMEs still covered by CSRD?

No. Listed small and medium-sized companies were originally in a later wave and are now outside mandatory scope altogether. The voluntary SME standard is what exists instead – and it doubles as the ceiling on what larger companies in your value chain are allowed to ask you for.

When do the revised ESRS apply?

From the 2027 financial year, with early application possible for 2026. The Commission adopted them in July 2026, they were published in the Official Journal on 21 September, and they come into force on 10 November 2026.