CSRD Omnibus I: what changed and what did not

An omnibus is one legislative proposal that amends several related laws at once. On 26 February 2025 the Commission published its Omnibus I package, bringing together proposals on sustainability reporting, due diligence, the EU Taxonomy and other areas. For corporate reporting it had two parts: a short “stop-the-clock” directive to postpone dates, and a longer directive to change the substance.

Both are now law. The substantive text is Directive (EU) 2026/470, adopted on 24 February 2026, which amends the Audit Directive, the Accounting Directive, the CSRD and the CSDDD. It entered into force on 18 March 2026. For what the CSRD requires in full, start with our CSRD guide; this page is about what the Omnibus changed.

The heart of the Omnibus is the new CSRD scope. Article 19a(1) of the consolidated Accounting Directivenow catches undertakings which “exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year”. Both must be exceeded. Switch between the two tables to see the same five rows before and after.

Those figures come from the Commission's staff working document SWD(2026) 500. The “1,750 employees” figure seen in some commentary after the December 2025 agreement is not in the adopted directive.

Two details catch people out. The Article 40a turnover test must be met in eachof the last two consecutive financial years, so one strong year does not bring a group in. And the €200 million subsidiary-or-branch test replaced two different old tests: a qualitative “large or listed” test for subsidiaries, and a €40 million test for branches.

Wave 1 companies, broadly large public-interest entities with more than 500 employees, have reported since financial year 2024. Those above the new thresholds carry on. Those below them fall out of mandatory scope from financial year 2027, once national law catches up.

For the gap years, Omnibus I lets each Member State exempt undertakings which “do not exceed a net turnover of EUR 450 000 000 or an average number of 1 000 employees” for financial years starting between 1 January 2025 and 31 December 2026. Note the OR: the option is wider than the scope test, and it is a national choice, so the answer differs by country.

Poland used it early. The Linklaters transposition tracker reports a Polish law, in force from 14 March 2026, that lets first-wave entities below at least one of the thresholds skip their FY2025 and FY2026 sustainability reports, provided they say so in the management report.

Worked through: a wave 1 bank with 1,500 employees and €400 million net turnover is below the €450 million limb, so it falls out of scope from FY2027. For FY2025 and FY2026 it is also inside the national option, because it does not exceed one of the two figures. Whether it can skip those two reports depends on whether its Member State took up the option.

A directive binds Member States, not companies, so the Omnibus reaches a company through the national law that transposes it. The Commission's record of what each Member State has notified is the EUR-Lex national transposition page for Directive (EU) 2026/470. We read it on 28 September 2026. The table lists every Member State that had notified anything.

Three cautions before reading anything into it. Nobody is late: the deadline for Articles 1 to 3, the CSRD, accounting and audit changes, is 19 March 2027, and for Article 4, the CSDDD changes, 26 July 2028. A notified measure is not a complete transposition: Belgium's changes one article, and Poland's Act predates the Directive's entry into force. And EUR-Lex states that Member States bear sole responsibility for what they notify, which does not prejudice the Commission's own check of completeness.

The delegated acts are different. The revised ESRS and the voluntary standard are regulations, binding in their entirety and directly applicable, so they need no transposition at all.

The cap matters most to UK suppliers. A reporter asking for more than it allows must say which information exceeds the cap and that the supplier has a statutory right to decline; a contract term to the contrary is not binding. The Commission's value-chain Q&A confirms it applies only to requests made for CSRD reporting. Suppliers should read our guide to the voluntary standard.

For the standards themselves, see what the revised ESRS contain. For the non-EU test, see our Article 40a guide, and for the assurance change, sustainability assurance explained. The same directive rewrote the due diligence rules too, covered on our CSDDD page.

Several things people expected to move did not. The most misreported is the EU Taxonomy. Directive (EU) 2026/470 amends four directives and no regulation, so the Taxonomy Regulation (EU) 2020/852 is unamended. Its Article 8 reporting still applies to companies reporting under Articles 19a and 29a of the Accounting Directive, so the population shrank automatically with the CSRD scope. The February 2025 idea of an optional Taxonomy band for smaller in-scope companies did not survive.

Taxonomy reporting was simplified separately, by Delegated Regulation (EU) 2026/73, which applies from 1 January 2026 and lets companies skip the eligibility and alignment assessment for activities below 10% of the relevant KPI, though the amounts must still be shown as non-material. Our taxonomy guide has the detail.

The double materiality test is explained on our double materiality page.

Run these for each legal entity and for the group; the checker at the top of the page runs the same tests on your figures. The answers depend on national law once it is in place, so treat them as a first screen. For UK groups, our CSRD guide for UK companies applies the same questions to UK structures.

The Omnibus moved different companies in different directions. Pick the description that fits; each tab says what applies, what to do next and by when.

The dates below come from the Commission's own CSRD policy-making timeline, the Official Journal and Dechert's September 2026 summary. The Stop-the-Clock Directive had its own transposition deadline of 31 December 2025. The timeline marks what has passed and what comes next on the day you read it.

OmnibusEU law-making

One legislative proposal that amends several related laws at once.

Omnibus I DirectiveDir (EU) 2026/470

The directive that amended the Audit Directive, the Accounting Directive, the CSRD and the CSDDD.

Stop-the-Clock DirectiveDir (EU) 2025/794

The short directive that postponed waves 2 and 3 by two years while Omnibus I was negotiated.

TranspositionArt 5(1)

A Member State bringing a directive into national law; due by 19 March 2027 for the CSRD articles.

National transposition measureEUR-Lex NIM

A national law a Member State notifies to the Commission as implementing a directive.

Wave 1CSRD

Companies reporting since financial year 2024, before Omnibus I changed the scope.

Member State optionArt 3(1)(c)

The national choice to exempt companies below €450m turnover or 1,000 employees for FY2025 and FY2026.

Protected undertakingArt 19a(3)

A value-chain undertaking with an average of 1,000 employees or fewer in the preceding financial year.

Article 40aAccounting Directive

The group-level report for non-EU groups with large EU turnover, from financial year 2028.