CSRD After Omnibus I: Who Still Has to Report, and From When
In brief
- The Omnibus I Directive, published in February 2026 and in force since 18 March 2026, cut the CSRD back to EU companies with more than 1,000 employees and more than €450 million net turnover.
- Non-EU groups are in scope only if they have more than €450 million turnover in the EU and an EU subsidiary or branch with more than €200 million.
- Companies newly in scope report first on financial year 2027, in 2028, using the simplified ESRS. EU countries must write the changes into national law by 19 March 2027.
- Smaller companies are protected by a “value-chain cap”: from financial year 2027, CSRD companies may not demand more from partners with up to 1,000 employees than the voluntary standard covers.
For two years, the CSRD was expected to cover around 50,000 companies. Omnibus I has changed that. Most SMEs, and many mid-sized groups, are now outside the law. But the data requests have not gone away: they now come through customers and banks, and they are limited by a new rule. Here is who still reports, from when, and what it means for the rest.
Who still has to report under the CSRD?
| Company | In scope? | First report |
|---|---|---|
| EU company with more than 1,000 employees and more than €450m net turnover (both tests) | Yes | Already reporting if in the first wave; otherwise financial year 2027, reported in 2028 |
| First-wave company now below the new thresholds | Leaving scope; EU countries may exempt it for financial years 2025 and 2026 | No reports once the new thresholds apply |
| Non-EU group: more than €450m EU turnover and an EU subsidiary or branch above €200m | Yes | Financial year 2028 |
| Companies with 1,000 employees or fewer | No | Can report voluntarily under the voluntary standard |
Check your national law as well as the directive. The changes take effect through transposition, which EU countries must complete by 19 March 2027, and some countries had already transposed the original CSRD in different ways.
What did Omnibus I change?
Besides the thresholds, three changes matter. First, the reporting standards, the ESRS, have been simplified: the Commission adopted revised, shorter standards in a delegated act in 2026, and newly covered companies will use those from the start. Second, the “value-chain cap” protects smaller partners from being asked for everything a large company must report. Third, the Commission adopted a voluntary reporting standard, based on the VSME, in a delegated act of 3 July 2026. It defines what a large company may ask its smaller partners for.
If you are not in scope: what you will still be asked
If you supply a company that reports under the CSRD, it still needs data on its value chain, especially Scope 3 emissions. From financial year 2027 it should limit its requests to companies with up to 1,000 employees to what the voluntary standard covers. In practice, that means energy, Scope 1 and 2 emissions, workforce, health and safety and similar items: the disclosures in the VSME Basic Module. Many banks are moving the same way for loan questionnaires.
This applies to non-EU suppliers too. A UK or Turkish manufacturer selling to a German group can expect the same request. Preparing one report to the voluntary standard, and sending it to everyone who asks, is usually simpler than answering each questionnaire separately.
Omnibus I took most companies out of the CSRD, but not out of their customers’ supply chains. The question has changed from “must we report?” to “what can they ask us for?”
What to do now
| Your situation | Next step |
|---|---|
| Above both thresholds, not yet reporting | Plan for financial year 2027 data; run a double materiality assessment under the simplified ESRS |
| First-wave company now below the thresholds | Check your country’s transposition for the 2025 and 2026 exemption before stopping work |
| Supplier to CSRD companies | Prepare a VSME report; see our [VSME report template guide](/article/vsme-report-template) |
| UK company with EU customers | Same as above; and check the UK rules in [UK SRS explained](/article/uk-sustainability-reporting-standards) |
Our sustainability reporting service helps suppliers prepare a VSME report, and the GHG accounting service covers the emissions part.
Frequently asked questions
Who must report under the CSRD after Omnibus I?
EU companies with more than 1,000 employees and more than €450 million net turnover, and non-EU groups with more than €450 million EU turnover and an EU subsidiary or branch above €200 million.
When do newly covered companies first report?
EU companies newly in scope report on financial year 2027, in 2028. Non-EU groups start with financial year 2028.
Are SMEs still affected by the CSRD?
Not directly. But their CSRD customers still need value-chain data. The value-chain cap limits what those customers may require from partners with up to 1,000 employees to the voluntary standard, from financial year 2027.
What is the value-chain cap?
A rule that stops companies reporting under the CSRD from requiring more sustainability information from smaller value-chain partners (up to 1,000 employees) than the Commission’s voluntary standard covers.
When must EU countries apply Omnibus I?
They must transpose the CSRD changes into national law by 19 March 2027.
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