# Does the CSRD apply to an Indian company that has an EU subsidiary or sells into the EU?

Canonical: https://senseible.earth/answers/does-csrd-apply-to-indian-companies

Only if the group is large in the EU. Selling into the EU without a subsidiary or branch does not bring an Indian company into CSRD scope. An EU subsidiary is in scope if it meets the EU size tests itself, and the whole Indian group reports only when its EU turnover crosses the third-country threshold.

## Three ways an Indian group can be caught

If none applies, the company has no CSRD reporting duty of its own.

1. Its EU subsidiary is in scope on its own size: after the Omnibus I amendment (Directive (EU) 2026/470), an EU company with more than 1,000 employees and more than €450 million net turnover.
2. The Indian parent is a third-country undertaking under Article 40a: net turnover generated in the EU above €450 million, with an EU subsidiary or branch above the size or turnover limit set in the amended text (reported as €200 million turnover).
3. Its securities are listed on an EU regulated market and it meets the size tests for listed issuers.

## Exporting alone does not trigger CSRD

An Indian manufacturer that ships to EU customers from India, with no EU subsidiary or branch, is outside CSRD scope however large its exports. What it will see instead are data requests from EU customers that report under CSRD. For suppliers with 1,000 or fewer employees, Directive (EU) 2026/470 caps what a CSRD reporter may require at the voluntary VSME-based standard, though a supplier may share more if it chooses.

## Who signs and files for a third-country group

Under Article 40a the EU subsidiary or branch publishes the group-level sustainability report, prepared for the non-EU parent's consolidated group. The report needs an assurance opinion. The Indian parent supplies the data, including Scope 1 and 2 emissions from its Indian plants, even though the EU entity files it.

## What to check now

- EU net turnover of the whole group for the last two financial years, not just exports billed by the Indian entity.
- Headcount and turnover of each EU subsidiary and branch.
- Whether any EU customer has asked for data beyond the VSME-based standard, which a smaller supplier may decline.

## What Senseible does here

Senseible turns the bills and invoices of Indian sites into document-backed Scope 1 and 2 figures that a group or its EU subsidiary can use in a sustainability report. Report drafts in Senseible are self-declared; it does not prepare ESRS statements or decide CSRD scope.

- [Who is still in scope of CSRD](https://senseible.earth/answers/who-is-still-in-scope-of-csrd)
- [CSRD double materiality for suppliers](https://senseible.earth/climate-intelligence/csrd-double-materiality-assessment-msme-supplier)
- [ESG reporting](https://senseible.earth/esg-reporting)

Sources: [Directive (EU) 2026/470 (Omnibus I) amending the CSRD, Directive (EU) 2022/2464](https://eur-lex.europa.eu/eli/dir/2026/470/oj/eng), [Council of the EU: simplification of sustainability reporting signed off, 24 February 2026](https://www.consilium.europa.eu/en/press/press-releases/2026/02/24/council-signs-off-simplification-of-sustainability-reporting-and-due-diligence-requirements-to-boost-eu-competitiveness/pdf/)

Last reviewed 2026-10-15. Confirm the Article 40a subsidiary and branch limits and the first reporting year in the adopted text of Directive (EU) 2026/470 and any national transposition.