CSRD after the Omnibus: new scope, simplified ESRS and timelines
The CSRD Omnibus is now law. Directive (EU) 2026/470, in force since 18 March 2026, limits the Corporate Sustainability Reporting Directive to EU companies with more than 1,000 employees and over €450 million turnover, and to non-EU groups with more than €450 million EU turnover. The simplified ESRS, adopted by the Commission in July 2026, cut mandatory datapoints by more than 60% and apply from financial years starting in 2027.
How we got here: stop-the-clock, then Omnibus I
The CSRD originally phased in from 2024 for about 50,000 companies. In February 2025 the European Commission proposed the Omnibus I simplification package. Two pieces followed:
- Stop-the-clock Directive (EU) 2025/794, in force since 17 April 2025, postponed reporting by two years for the second wave (large companies not yet reporting) and the third wave (listed SMEs). First-wave companies kept reporting.
- Omnibus I Directive (EU) 2026/470, published in the Official Journal on 26 February 2026 and in force from 18 March 2026, rewrote the CSRD's scope, assurance and value-chain rules. Member States have until 19 March 2027 to transpose the CSRD changes.
A third piece, the revised ESRS, came as a delegated act. The Commission adopted it on 3 July 2026 and, after the scrutiny period, it was published in the Official Journal in September 2026.
CSRD scope after the Omnibus
| Company type | Threshold | First financial year |
|---|---|---|
| EU company or group | More than 1,000 employees and net turnover above €450 million | Starting in 2027 (report in 2028) |
| Non-EU ultimate parent | EU net turnover above €450 million in each of the last two years, plus an EU subsidiary or branch with turnover above €200 million | Starting in 2028 (report in 2029) |
| Listed SMEs | Removed from scope | Not applicable |
| Pure financial holding companies | Exempt if they do not take part in managing their subsidiaries | Not applicable |
The previous large-undertaking test (two of: 250 employees, €25 million balance sheet, €50 million turnover) no longer applies. Most companies once expected in the second wave are now out of scope. Member States may also exempt first-wave companies that fall below the new thresholds from reporting for financial years 2025 and 2026. Whether that option applies depends on national transposition, so check the law where your entity is established.
The Commission must review the thresholds, and whether high-risk sectors need different treatment, by 26 July 2031.
Simplified ESRS: what changed
The revised ESRS keep the same topics: ESRS 1 and 2 cross-cutting standards, five environmental, four social and one governance standard. What changed is how much has to be reported and how.
- Fewer datapoints — the Commission reports a cut of more than 60% in mandatory datapoints and more than 70% overall.
- Double materiality stays — but a top-down assessment is now allowed, alone or combined with bottom-up work, and companies only need to consider each year whether a refresh is needed.
- Only material information — reporting non-material information is generally not allowed, with limited exceptions.
- Undue cost or effort relief — companies can skip gathering information that would involve undue cost or effort, reassessed each period.
- Value-chain flexibility — wider use of estimates and proxies, with explanations of efforts and plans in the first three years.
- Phase-ins — new reporters starting in 2027 can omit anticipated financial effects for their first two reporting years, and the quantitative information for their first four.
- Opportunities — limited to those the company is actually pursuing or has built into strategy.
The revised ESRS apply to financial years beginning on or after 1 January 2027. For financial year 2026, companies already reporting may apply them early or keep using the 2023 standards. The Commission no longer has a mandate to adopt sector-specific ESRS; it may issue guidance instead.
Sector standards, assurance standards and national transposition are still moving. Treat any summary, including this one, as a starting point and confirm the text that applies to your entity.
Assurance and the value-chain cap
Limited assurance only
The planned move to reasonable assurance has been dropped. Sustainability reports still need limited assurance, and the Commission is due to adopt harmonised limited assurance standards by 1 July 2027.
The value-chain cap
Companies with no more than 1,000 employees are protected from excessive data requests. A CSRD reporter cannot require them to provide more sustainability information than the voluntary standard sets out, and cannot impose it through contracts. The Commission adopted that voluntary standard by delegated act alongside the revised ESRS. Reporters may still ask for greenhouse gas data needed for their own E1 climate metrics, and normal commercial information exchange is unaffected.
What non-EU groups and suppliers should do
Non-EU parents with EU business
- Test the two-year €450 million EU turnover condition and the €200 million subsidiary or branch condition now; the first financial year in scope is 2028.
- Check whether any EU subsidiary is in scope on its own from 2027.
- Decide whether to report at group level and confirm which standards will be accepted for non-EU parents under the Omnibus rules.
- If you already report under IFRS S2, map your climate data to ESRS E1 to reuse it.
Suppliers to EU companies
Most suppliers in India, the Middle East and Asia will not be in CSRD scope. They will still receive requests from customers who are. The value-chain cap limits what can be demanded from smaller suppliers, but emissions data remains the most common request, and it overlaps with CBAM and with customers' Scope 3 programmes. A clean Scope 1 and 2 inventory, product-level footprints where relevant and a short evidence pack will cover most requests. Our guide to answering customer sustainability questionnaires covers this in detail.
How EKOTRACE helps
EKOTRACE supports double materiality assessments, ESRS disclosures and a content index export alongside GRI, ISSB/IFRS S1-S2, BRSR and CDP, using one approved emissions dataset. Scope 1, 2 and all 15 Scope 3 categories are calculated with versioned emission factors and maker-checker approvals, giving assurance providers a clear audit trail. See ESG reporting.
For suppliers, the EKOTRACE supplier portal lets EU customers request data, and lets you share only what is asked for. See supplier engagement and CBAM compliance.
Frequently asked questions
Has the CSRD Omnibus been adopted?
Yes. Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. Member States must transpose the CSRD changes by 19 March 2027.
Who is in CSRD scope in 2026?
Only first-wave companies are reporting for 2025 and 2026, and Member States may exempt those that fall below the new thresholds. EU companies with more than 1,000 employees and over €450 million turnover start with financial years beginning in 2027.
When do the simplified ESRS apply?
The revised ESRS apply to financial years beginning on or after 1 January 2027. Companies reporting for financial year 2026 may apply them early.
Is double materiality still required under the CSRD?
Yes. The revised ESRS keep double materiality, covering both impacts and financial effects. They allow a simpler top-down approach and do not require a full reassessment every year.
Does the CSRD apply to Indian or Middle Eastern companies?
Directly, only if the group has more than €450 million EU turnover and a large EU subsidiary or branch, from financial year 2028. Indirectly, many suppliers will receive data requests from EU customers who report.