A parent must include sustainability information in the consolidated management report only where the group, on a consolidated basis at the balance sheet date, exceeds both EUR 450 million net turnover and 1,000 average employees.
The requirement, in our words
A parent undertaking must include sustainability information in the consolidated management report only where its group, on a consolidated basis at the balance sheet date, exceeds both EUR 450 million net turnover and an average of 1 000 employees averaged over the year. The content explains how the group affects people and the environment and how sustainability issues bear on its results, position and outlook.
Why it matters
The group test mirrors the individual test but uses consolidated figures. It is the provision that decides whether a group produces one consolidated statement or leaves each subsidiary to apply its own individual test. The answer can differ from the individual answer: a group can be above both figures while an individual subsidiary is below them, and the exemption in Article 29a(9) may then apply to the subsidiary.
What changed
The old Article 29a(1) applied to large groups. The replacement sets the two-figure test for financial years starting on or after 1 January 2027, aligned with the individual threshold.
What to do
- Calculate consolidated net turnover and average group headcount at the balance sheet date.
- Record the consolidation perimeter and the entities included in each figure.
- Have the parent board or audit committee approve the scoping conclusion.
Evidence to have ready
| Category | Artefact |
|---|---|
| Scoping | Consolidated threshold calculation with group turnover and average group headcount at the balance sheet date |
| Scoping | Scoping conclusion approved by the parent's board or audit committee |
| Scoping | Consolidation perimeter list used for the headcount figure |
Common failures
- Headcount taken from a single entity rather than the consolidated group
- Threshold test run on the financial reporting perimeter while the sustainability perimeter differs without explanation
Dates
Financial years starting on or after 1 January 2027. Transposition by 19 March 2027.
The question to test
Are the turnover and headcount figures consolidated, and do they match the perimeter used for the financial statements?
Cross-references
A2-3 Individual statement threshold · A2-7 Subsidiary exemption · A2-9 Group value chain cap
Source
Article 2(5)(a), replacing the first subparagraph of Article 29a(1) of Directive 2013/34/EU; OJ L 2026/470, 26 February 2026; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026L0470. Our statement of the duty, read from the Official Journal text and the held control record, not the instrument verbatim.
Not legal advice; does not certify. A reading of the duty and the evidence commonly sampled, not a substitute for the Official Journal text, the national transposing measure or your auditor's judgement.