The EU Omnibus: What Changed for CSRD in 2026

Introduction

The Omnibus I directive (Directive (EU) 2026/470) is the most significant rewrite of EU sustainability reporting since the Corporate Sustainability Reporting Directive (CSRD) itself. In force since 18 March 2026, it removed roughly 90 per cent of companies from mandatory scope, put a legal ceiling on the ESG data large companies may demand from smaller business partners, and simplified the reporting standards.

If you read something about CSRD written before March 2026, treat its scope and deadline claims with caution: much of it no longer applies. This page summarises what changed, what it means depending on where your company sits, and what is still in motion. We keep it current as the remaining pieces land.

The timeline at a glance

Change 1: Far fewer companies report

Before Omnibus I, CSRD scope was based on a “two of three” test: 250 employees, €50 million turnover, or a €25 million balance sheet, with listed SMEs due to follow in a later wave. Omnibus I replaced all of that with a single test. A company reports only if it meets both conditions:

Three groups left mandatory scope as a result:

• Mid-sized companies of 250 to 1,000 employees are out
• Listed SMEs are out: the entire listed-SME reporting track was eliminated, not postponed
• All other SMEs were never in scope and now definitively are not

Non-EU groups are covered only when the parent generates more than €450 million of EU turnover and has an EU subsidiary or branch above €200 million. If you are unsure where your company falls, our guide to whether your company is too small for CSRD walks through it.

Change 2: The value-chain cap

The companies still in scope must report on their value chains, which is why smaller suppliers receive ESG questionnaires. Omnibus I put a legal boundary around that: a CSRD reporter may not require more sustainability information from a business partner with fewer than 1,000 employees than the voluntary SME standard defines.

The delegated act adopted on 3 July 2026 fixes this ceiling to the standard’s Annex II, with a lower cap for micro-enterprises of 10 or fewer employees. The cap applies fully to financial years starting 1 January 2027, and many large buyers are redesigning their supplier questionnaires around it now.

The cap is real but not absolute. Information customarily exchanged in a sector, or required by other EU law, sits outside it, as do climate targets, climate-risk questions, and platform assessments such as EcoVadis. Our guide to what large customers can ask suppliers covers the detail.

Change 3: Simplified reporting standards

For companies still in scope, the European Sustainability Reporting Standards (ESRS) were revised alongside the scope change. The headline simplification concerns materiality: only ESRS 2 (General Disclosures) remains mandatory for every reporter. Each topical standard, from climate through business conduct, is included only where the company’s double materiality assessment flags it as material, and the assessment itself is lighter and more top-down than before.

The revised ESRS were adopted by the Commission on 3 July 2026 and apply to financial years starting 1 January 2027, with early adoption possible for 2026. At the time of writing they are in the European Parliament and Council scrutiny period, which can confirm or object to the adopted text.

Change 4: A voluntary standard with legal weight

The Voluntary Sustainability Reporting Standard for SMEs (VSME), published by EFRAG, was a recommendation until Omnibus I made it load-bearing. The 3 July 2026 delegated act turns it into the voluntary standard (VS) that defines the value-chain cap: from financial year 2027, the VS is the legal reference point for what may be asked of smaller companies.

The standard keeps its two-module shape: a Basic Module of eleven disclosures and a Comprehensive Module with further detail on strategy, targets, and climate. For a company choosing between them, see VSME Basic vs Comprehensive Module.

What it means for you

If your company is in scope (more than 1,000 employees and more than €450 million turnover): your obligation continues, but against fewer datapoints and a lighter materiality process. The revised standards apply from financial year 2027; the largest public-interest companies continue reporting in the meantime. Check your dates in our CSRD deadlines by country reference.

If your company is not in scope, which is the vast majority: you file nothing under CSRD, and that is now settled law rather than a postponement. What continues is the commercial pressure. Customers, banks, and tenders keep asking for ESG data, and the value-chain cap now defines what a reasonable request looks like. A voluntary VSME report remains the most efficient way to answer them all with one document.

What is still in motion

• Parliamentary scrutiny. The 3 July delegated acts sit in a scrutiny period of two months, extendable to four. Objection is uncommon but possible; we will update this page when scrutiny concludes.
• National transposition. Member states are aligning their national laws with Omnibus I. Country specifics can shift dates and administrative details, though not the core scope test.
• Buyer behaviour. Large companies have until financial year 2027 to bring supplier questionnaires within the cap. Expect a mixed picture in the meantime, with some requests still exceeding what the standard defines.

Frequently Asked Questions

Did the Omnibus cancel CSRD?

No. CSRD remains in force for the largest companies, roughly those with more than 1,000 employees and more than €450 million turnover. What the Omnibus did was narrow the scope dramatically, simplify the standards, and cap what in-scope companies may ask of smaller business partners.

Are SMEs ever required to report under CSRD now?

No. The listed-SME reporting track was eliminated entirely, and no company under the thresholds is a mandatory filer. SMEs report voluntarily, if at all, using the VSME standard, usually because a customer or bank has asked for the data.

When do the changes actually apply?

The scope change and the value-chain cap have been law since 18 March 2026. The revised ESRS and the voluntary standard apply to financial years starting 1 January 2027, with early adoption possible from 2026.

What is the difference between Stop-the-Clock and Omnibus I?

Stop-the-Clock (April 2025) only delayed reporting dates by two years and changed nothing about who reports. Omnibus I (March 2026) changed the substance: who is in scope, what the standards require, and what suppliers can be asked for.

Key Terms

• Omnibus I: Directive (EU) 2026/470, in force 18 March 2026, which narrowed CSRD scope, simplified the ESRS, and created the value-chain cap.
• Stop-the-Clock: Directive (EU) 2025/794, the April 2025 measure that deferred reporting waves by two years without changing scope.
• Value-chain cap: the legal limit on the sustainability information a CSRD reporter may require from business partners with fewer than 1,000 employees.
• VSME / VS: EFRAG’s Voluntary Sustainability Reporting Standard for SMEs, adopted in July 2026 as the “voluntary standard” that defines the cap from financial year 2027.
• ESRS: the European Sustainability Reporting Standards that in-scope companies report against, revised by delegated act in July 2026.
• Delegated act: legislation the European Commission adopts under powers granted by a directive, subject to Parliament and Council scrutiny before it settles.

Conclusion

The Omnibus turned CSRD from a broad mandate into a narrow one with a defined edge: a small set of very large reporters, a legal cap protecting everyone beneath them, and a voluntary standard that carries the weight. Whichever side of the line your company sits on, the rules are now clearer than they have been at any point since CSRD was adopted.

This page is maintained as the remaining pieces land, so it is safe to link to and to cite.