CSRD after Omnibus I (Directive (EU) 2026/470): who still reports?

Who is still in scope?

Omnibus I, Directive (EU) 2026/470, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. It rewrites the Corporate Sustainability Reporting Directive (CSRD) scope around two thresholds that must both be exceeded:

• an average of more than 1,000 employees during the financial year; and
• net turnover above €450 million.

The same test applies at three levels: an individual undertaking, a parent measured on its consolidated group, and an issuer with securities on an EU regulated market. Companies below either threshold are out of mandatory reporting, although they may report voluntarily.

Two groups lose their obligation entirely. Listed SMEs, which were due to report later in the phase-in, are removed from the regime. First-wave companies that reported for 2024 (large public-interest entities with more than 500 employees) stay subject to the old rules only for financial years 2024 to 2026; from 2027 they report only if they meet the new thresholds, and Member States may exempt those below the thresholds for 2025 and 2026.

What changed for non-EU groups?

Non-EU groups report through their EU subsidiaries or branches, and Omnibus I raises both triggers:

• the group's net turnover in the EU must exceed €450 million in each of the last two consecutive financial years (previously €150 million); and
• the EU subsidiary or branch that publishes the report must have net turnover above €200 million.

These reports apply to financial years starting on or after 1 January 2028. Financial holding groups whose subsidiaries run independent businesses may choose not to publish the group report.

What happened to assurance?

Sustainability reports still need an assurance opinion from a statutory auditor or, where a Member State allows it, an accredited independent assurance provider. Two things changed:

• Only limited assurance. The Commission's power to adopt reasonable-assurance standards, planned for 2028, is deleted.
• Standards later. The deadline for the Commission's limited-assurance standards moves from 1 October 2026 to 1 July 2027.

A transitional regime also lets non-EU auditors that assure the reports of non-EU companies listed in the EU register under simpler conditions for financial years 2025 to 2030.

What happens to the ESRS and value-chain requests?

Reports still follow the European Sustainability Reporting Standards (ESRS) and the double-materiality principle. The Commission adopted revised ESRS on 3 July 2026, cutting mandatory datapoints by more than 60% and total datapoints by more than 70%. EFRAG states that they apply to financial years beginning on or after 1 January 2027, with voluntary use for 2026 once the delegated act is in force.

Omnibus I also:

• drops sector-specific standards, which were due by 30 June 2026; and
• caps value-chain requests. Companies in scope may not require suppliers with up to 1,000 employees to provide more than the voluntary reporting standard covers.

What are the next dates?

• 17 April 2025: the "stop-the-clock" Directive (EU) 2025/794 entered into force, postponing the second wave to financial year 2027.
• 18 March 2026: Omnibus I entered into force.
• 19 March 2027: Member States must transpose the CSRD changes into national law.
• 1 July 2027: deadline for the Commission's limited-assurance standards.
• Financial year 2027: first reports under the new thresholds, published in 2028.
• Financial year 2028: first reports by non-EU groups.

Omnibus I also amended the Corporate Sustainability Due Diligence Directive: Member States now transpose it by 26 July 2028 and apply it from 26 July 2029.

What should companies now out of scope do?

Leaving the mandatory regime does not end the questions. Banks, investors and large customers still ask for emissions, workforce and governance data, and the value-chain cap only limits what CSRD reporters can demand of you.

1. Confirm your position against both thresholds, at company and group level, and watch your national transposition law.
2. Keep the data you already built. Emissions inventories and policies remain useful for customers and lenders.
3. Answer requests with the voluntary standard so one data set serves every customer.
4. Track headcount and turnover each year. Crossing both thresholds brings you back into scope.

If you are still in scope, our CSRD guide covers double materiality and the ESRS. Treating disclosures as evidence tied to owned controls, the same way you run evidence collection for security audits, makes limited assurance easier.