CSRD Omnibus Simplification: What Changed and Who Must Still Report

The CSRD Omnibus is the EU’s simplification of its sustainability reporting rules. It is no longer a proposal: it was adopted as Directive (EU) 2026/470, entered into force on 18 March 2026, and applies from financial year 2027. It sharply narrowed who has to report under the Corporate Sustainability Reporting Directive (CSRD) and trimmed what they disclose.

This guide covers the change itself: what the Omnibus did, who is now in or out of scope, and what it left untouched. For how to actually comply once you know you are in scope, see CSRD reporting requirements. For what the climate standard (ESRS E1) demands, see CSRD climate risk disclosure.

Three instruments changed CSRD, not one

“The Omnibus” is shorthand for three separate measures that together reshaped who reports, when, and how much.

In plain terms: one directive cut the scope, one bought time, and one eased the load on the companies already reporting.

The scope change: from a wide net to the largest companies

This is the headline. The original CSRD pulled in any large EU undertaking meeting two of three tests: more than 250 employees, more than EUR 50 million in net turnover, or more than EUR 25 million in balance sheet total. The Omnibus replaced that with a single, much higher gate.

Both new conditions must be met. The turnover test matters as much as the headcount test: a company with 2,000 employees but under EUR 450 million in turnover is now out. The Commission has indicated the change cuts the in-scope population from roughly 50,000 to around 5,000 companies. (That count is a Commission and adviser estimate; the directive text does not state a number.)

For the exact criteria and the non-EU rules, the authoritative statement is on the CSRD reporting requirements page.

Who dropped out, and who is still in

The scope cut is large, so the practical question for most companies is simply: am I still in?

You are out if you fall below either gate: under EUR 450 million in net turnover, or 1,000 employees or fewer. Listed small and medium-sized enterprises are out entirely. This removes not only the smaller companies that were originally going to phase in later, but also a band of sizeable employers that sit below the EUR 450 million turnover line. Member States may let companies that fall out stop reporting even for the financial years beginning in 2025 and 2026.

You are still in if you exceed both EUR 450 million in net turnover and 1,000 employees. Non-EU groups are in where they generate more than EUR 450 million of EU turnover and have a qualifying EU subsidiary or branch (the thresholds are on the reporting-requirements page).

In plain terms: the test is no longer “are you a large company,” it is “are you one of the largest.” If you are unsure, check both numbers, because clearing one is not enough.

What the Omnibus and Stop-the-Clock changed about the timeline

The reporting schedule shifted twice. The Stop-the-Clock directive delayed the second and third waves by two years, and the Omnibus then narrowed who those waves contain.

The companies already reporting (the first wave of large public-interest entities) continue on FY 2024 to 2026. From FY 2027 the new turnover-and-headcount scope applies, and companies below it leave the system. The third wave (listed SMEs) was eliminated. For the precise filing dates by group, see the timeline on the CSRD reporting requirements page.

What else the Omnibus simplified

Beyond scope, the package made four changes worth knowing. Each is summarized here; the operative detail lives on the reporting-requirements page. The same package also amended the due diligence directive on its own timeline. Our CSDDD vs CSRD comparison maps which obligations sit under which directive.

• Fewer data points. The Omnibus mandated a revision of the ESRS standards to remove the least important data points, favor quantitative metrics over narrative, and clarify which are mandatory. The original set ran to over 1,000 data points; the revision is expected to cut that substantially.
• Sector-specific standards dropped. The plan to issue industry-specific ESRS was deleted.
• Assurance eased. The path that would have escalated assurance from limited to the stricter reasonable level was removed. Limited assurance stays.
• Value-chain cap added. Companies with 1,000 employees or fewer in a reporter’s value chain can refuse data requests beyond the voluntary-standard limits.

What did not change

The Omnibus narrowed the regime; it did not dismantle it. For companies still in scope, the core is intact:

• Double materiality remains the assessment basis (financial and impact).
• The 12 ESRS standards still structure the disclosures.
• Climate (ESRS E1) is still the one topic a company must justify in detail if it claims to be immaterial. What E1 demands on climate and physical risk is covered in CSRD climate risk disclosure.
• Limited assurance is still mandatory.

In plain terms: if you remain in scope, what you report and how you assure it is largely unchanged. The Omnibus mostly changed who has to do it.

What to do now

If you are still in scope (above EUR 450 million turnover and 1,000 employees), the requirements stand and the preparation runway is the same. The step-by-step is on the CSRD reporting requirements page.

If you are newly out of scope, mandatory reporting falls away, but two things remain. You can report voluntarily using the EU’s voluntary standard for smaller companies, which many do to satisfy lenders and large customers. And if you sit in the value chain of a company that is still in scope, you may still receive data requests, now capped at the voluntary-standard level.

Frequently asked questions

What is the new threshold for CSRD reporting?
An EU company is in scope only if it exceeds both EUR 450 million in net turnover and 1,000 employees on average. This replaced the original test (250 employees and two of three size criteria). The change cut the in-scope population from roughly 50,000 to about 5,000 companies.

Is the Omnibus still a proposal?
No. It was adopted as Directive (EU) 2026/470, entered into force on 18 March 2026, and applies from FY 2027. Member States have 12 months to write it into national law.

Is CSRD being delayed or scrapped?
Neither. The Stop-the-Clock directive delayed the later waves by two years, and the Omnibus narrowed scope, but the CSRD remains in force for the largest companies. The first wave continues to report.

Who must still report under the CSRD?
EU companies above both EUR 450 million in net turnover and 1,000 employees, and non-EU groups with more than EUR 450 million of EU turnover plus a qualifying EU subsidiary or branch. Listed SMEs are exempt.

Does the Omnibus change the climate (ESRS E1) requirements?
The scope and data-point simplification apply to E1 like every standard, but climate’s special status is unchanged: it is still the topic a company must justify if it claims to be immaterial. See CSRD climate risk disclosure.

Sources

1. Directive (EU) 2026/470 (Omnibus I), amending Directives 2022/2464, 2013/34/EU, 2006/43/EC and 2004/109/EC. EU scope (net turnover over EUR 450 million and more than 1,000 employees); non-EU thresholds; FY 2027 application and the FY 2025-2026 Member-State exemption; value-chain cap; sector-specific deletion; assurance change; ESRS revision mandate. Adopted 24 February 2026, OJ 26 February 2026, in force 18 March 2026.
2. Stop-the-Clock (Directive (EU) 2025/794): two-year delay of the later reporting waves.
3. Wave 1 Quick Fix (Commission delegated act, July 2025): deferral of quantitative financial-effects figures for FY 2025-2026.