CSRD after the Omnibus: who reports and when

What did the Omnibus change in the CSRD?

The CSRD originally applied to large EU companies meeting two of three tests, more than 250 employees, more than 50 million euros of net turnover or more than 25 million euros of total assets, and to listed small and medium-sized companies, phased in from 2024. In February 2025, the European Commission proposed an Omnibus package to simplify sustainability rules. A first directive, known as stop-the-clock, delayed later reporting waves by two years. The Omnibus I Directive then changed the scope itself: it was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. See sustainability reporting explained.

Who is in scope of the CSRD after the Omnibus?

• EU companies and groups with more than 1,000 employees and net annual turnover above 450 million euros, both tests together, measured at group level for groups.
• Non-EU groups whose ultimate parent is outside the EU, with more than 450 million euros of net turnover in the EU in each of the last two consecutive financial years and an EU subsidiary or branch with net turnover above 200 million euros.

Companies below the thresholds are outside mandatory reporting but can report voluntarily, and the EU has adopted a voluntary standard designed for them.

CSRD after the Omnibus: four companies

Consider four groups and how the new tests apply to them.

The German group is in scope because it exceeds both thresholds; if it was not already reporting, its first report covers its 2027 financial year. The French company has the turnover but not the employees, and the Dutch company the employees but not the turnover, so both are out: the two tests must both be met. The US group is in scope as a non-EU group because its EU turnover and its German subsidiary both exceed the thresholds, with reporting from its 2028 financial year.

When do companies start reporting?

EU companies in scope that were not already reporting start with financial years beginning in 2027, publishing in 2028. Non-EU groups start with financial years beginning in 2028, publishing in 2029. Companies already reporting since 2024, known as wave 1, continue if they meet the new thresholds, using the revised ESRS from 2027, with options for 2026. Those below the thresholds leave the CSRD from 2027, and member states may exempt them from reporting for their 2025 and 2026 financial years. See the revised ESRS and CSRD wave 1 relief.

What happened to assurance?

The original CSRD foresaw a move from limited to reasonable assurance. The Omnibus removed reasonable assurance, so sustainability statements need only limited assurance, in which the provider reports that nothing has come to its attention to suggest the statement is materially misstated. The Commission must adopt standards for limited assurance by 1 July 2027. See sustainability assurance explained. The two levels are compared in limited and reasonable assurance.

How are smaller suppliers protected?

Large companies need data from their value chains, such as suppliers' emissions. The Omnibus introduced a value chain cap: companies reporting under the CSRD cannot require value chain companies with fewer than 1,000 employees to provide information beyond what the voluntary standard covers, applying from financial years beginning on or after 1 January 2027. Suppliers can still choose to share more. See the value chain cap and the voluntary standard.

What happens next?

Member states must transpose the changes into national law by 19 March 2027, and some details, such as the wave 1 relief, depend on national choices. Companies near the thresholds should check their employee numbers and turnover, including at group level, and non-EU groups should track their EU turnover over two consecutive years. The CSRD links to other EU rules: Taxonomy reporting and the Corporate Sustainability Due Diligence Directive were also changed by the Omnibus. See IFRS S2 for groups also reporting under the ISSB standards elsewhere. Non-EU groups are covered in more detail in the CSRD for non-EU companies. For the Taxonomy changes, see EU Taxonomy reporting after the Omnibus.

This guide is general information. It is not tax or legal advice for your situation.