NESRS — Standards for Non-EU Groups (CSRD Article 40a)

Definition

NESRS are the European Sustainability Reporting Standards for Non-EU Groups — the standards that non-EU parent companies (including Indian-headquartered groups) will use to report consolidated sustainability information at the EU-operations level under Article 40a of the CSRD (Directive (EU) 2022/2464).

NESRS sit in the broader EU sustainability reporting standards family alongside ESRS Set 1 (for EU large undertakings + EU-listed entities) and VSME (the voluntary SME standard). NESRS are specifically for third-country undertakings exceeding the EU-operations thresholds.

Who is in NESRS scope (post-Omnibus I, in force March 2026)

A non-EU parent group must report under NESRS when both of the following are met:

1. EU consolidated net turnover above €450 million for two consecutive financial years, AND
2. An EU subsidiary or branch with net turnover above €200 million (the €200M test is a flat threshold applying to whichever EU presence the group has — there is no separate, lower branch threshold).

These post-Omnibus I thresholds are materially higher than the original CSRD numbers (€150M EU turnover + €40M branch). The change was published in OJEU on 26 February 2026 via Directive (EU) 2026/470 and entered into force on 18 March 2026.

Timeline

Date	Event
By 30 June 2026	European Commission mandated to adopt NESRS as a delegated act (per CSRD Article 40a; deadline was confirmed via Directive (EU) 2024/1306)
FY 2028	First reporting year for in-scope non-EU parent groups
2029	First NESRS sustainability reports due (covering FY 2028)

EFRAG’s research-phase output has informed the EC’s draft preparation. The published standards are expected to be lighter than full ESRS Set 1 — focused on the entity’s EU-attributable activities and impacts, rather than the entire global group.

What NESRS will cover (expected scope)

Per CSRD Article 40a, the NESRS sustainability report at parent-group level should cover the non-EU parent’s EU-attributable activities, including:

• Information on the group’s impact on sustainability matters
• Environmental, social, and human-rights matters
• Governance arrangements relevant to the EU operations
• Information equivalent to that required under ESRS Set 1 — but proportionate to the EU-attributable scope

The standards are not yet finalised; expected EC adoption is by 30 June 2026.

India relevance

NESRS will be operationally relevant to Indian-headquartered groups that:

• Have material EU subsidiaries individually exceeding €200M net turnover, AND
• Have consolidated EU operations exceeding €450M net turnover for two consecutive years

This is a much narrower population than the pre-Omnibus regime would have captured. Likely candidates include large Indian IT services groups with multiple EU subsidiaries (Infosys, TCS, Wipro, HCLTech, Tech Mahindra), pharmaceutical groups with EU formulation + distribution arms (Sun Pharma, Dr Reddy’s, Cipla, Lupin), and large industrial groups with European acquisitions or operations (Tata Motors via JLR, Mahindra Group, Reliance Industries via specific EU subsidiaries).

For these entities, the NESRS report is a separate workstream from SEBI’s BRSR (which continues independently at the Indian listed-entity level). The data infrastructure that supports BRSR Core Assurance — boundary documentation, GHG inventory methodology, workforce data, water and waste registers — also supports the NESRS EU-operations report, but the disclosure structure and assurance chain are different.

Related terms

• CSRD Disclosure Framework methodology page — full walkthrough including the three India-relevance cases and the post-Omnibus scope
• CSRD — the EU directive under which NESRS sits
• ESRS — the parent standards family
• VSME — the voluntary SME standard that also acts as the value-chain cap ceiling
• BRSR — India’s parallel listed-entity sustainability reporting framework
• CBAM — the parallel EU regime on embedded-emissions carbon pricing