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Simplification · RPT-09

Third-country group sustainability reporting duty on EU subsidiaries/branches now applies only above raised turnover thresholds

Addressee EU subsidiaries and branches of third-country undertakingsAct COM(2025) 81, 2025/0045 (COD)Article Art. 2(12), amending Art. 40a(1) of Directive 2013/34/EUClass Businesses

What changes

Third-country groups whose EU turnover sits between the old (EUR 150m parent / EUR 40m branch) and new (EUR 450m parent / EUR 50m branch) thresholds lose the group-level sustainability-disclosure duty entirely.

Prior rule vs new rule

Prior rule
Trigger

Third-country parent turnover in the Union > EUR 150 000 000 (subsidiary route) or EU branch turnover > EUR 40 000 000 (branch route)

Obligation

Pursuant to Article 40a(1), fourth and fifth subparagraph of Directive 2013/34/EU, a subsidiary in the Union of a third-county undertaking that generates a net turnover of more than EUR 150 million in the Union, or, in the absence of such subsidiary, a branch in the Union that generates a net turnover of more than EUR 40 million, is to publish and make accessible sustainability information at the group level of the third-country parent undertaking.

New rule
Trigger

Third-country parent's net turnover in the Union exceeding EUR 450 000 000 for each of the last two consecutive financial years (raised from EUR 150 000 000); branch threshold raised from EUR 40 000 000 to EUR 50 000 000

Obligation

Third-country group sustainability reporting duty on EU subsidiaries/branches now applies only above raised turnover thresholds

Who is affected

Addressee
EU subsidiaries and branches of third-country undertakings
Class
Businesses
Sectors
No sector named — applies by size or activity
Applies
Once transposed by Member States (transposition due within 12 months of this Directive's entry into force)

Burden drivers

No burden drivers recorded on this provision.

The threshold is the third-country parent's EU turnover, not your own employee count.

Source text

Verbatim

The first and third subparagraphs shall only apply to the subsidiary undertakings or branches referred to in those subparagraphs where the third-country undertaking, at its group level, or, if not applicable, the individual level, generated a net turnover in the Union exceeding EUR 450 000 000 for each of the last two consecutive financial years.

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