CSRD Omnibus I: what changed and what did not

It is law, not a proposal.

The Commission proposed it on 26 February 2025, it was adopted as Directive (EU) 2026/470 on 24 February 2026, published in the Official Journal on 26 February 2026 and in force from 18 March 2026.

Member States must transpose the CSRD changes by 19 March 2027.

The revised ESRS and the voluntary standard that complete it were published on 21 September 2026.

An EU undertaking, EU group parent or EU-listed issuer is in scope if it exceeds both an average of 1,000 employees and €450 million of net turnover in the financial year.

A non-EU group is in scope under Article 40a if it has more than €450 million of EU net turnover in each of the last two consecutive financial years and an EU subsidiary or branch above €200 million.

The main wave caught every “large” undertaking: one exceeding at least two of €25 million balance sheet, €50 million net turnover and 250 employees, under Article 3(4) of the Accounting Directive.

Listed SMEs were in a later wave.

That test still defines a large undertaking for accounting purposes, but it no longer sets CSRD scope.

Yes.

Omnibus I narrowed the CSRD but kept it.

The largest EU companies and groups still report under the ESRS with limited assurance, non-EU groups with large EU turnover follow from financial year 2028, and smaller companies feel it through the value-chain cap.

An omnibus is a single legislative proposal that amends several related laws at once.

Omnibus I amended the Audit Directive, the Accounting Directive, the CSRD and the CSDDD in one directive, Directive (EU) 2026/470, alongside the separate Stop-the-Clock Directive (EU) 2025/794 that postponed dates while it was negotiated.

The wave-one rules are limited to financial years 2024 to 2026.

For FY2025 and FY2026 each Member State may exempt companies that do not exceed €450 million net turnover or 1,000 employees — an OR test, wider than the scope test.

From FY2027 companies below both new thresholds fall out of mandatory scope.

Wave one companies that remain in scope keep reporting.

Other in-scope companies start with financial years beginning on or after 1 January 2027 and report in 2028, under the revised ESRS.

The value-chain cap applies from the same year.

Article 40a group reports start with financial year 2028, published in 2029.

On the EUR-Lex transposition page read on 28 September 2026, four Member States had notified measures: Belgium one, Croatia two, Poland one and Finland two.

The other 23 had notified none.

That is not lateness, because the deadline for the CSRD articles is 19 March 2027, and a notified measure is not necessarily a complete transposition.

No. Directive (EU) 2026/470 amends four directives and no regulation.

Taxonomy Article 8 reporting still binds companies reporting under Articles 19a and 29a of the Accounting Directive, so its population shrank with the CSRD scope.

The idea of optional Taxonomy reporting for a band of smaller companies did not survive.

Separate simplifications came through Delegated Regulation (EU) 2026/73, from 1 January 2026.

Yes, in its Article 4.

It raised the CSDDD thresholds to more than 5,000 employees and €1.5 billion turnover, set one application date of 26 July 2029, deleted the transition plan duty in Article 22 and removed the EU-wide civil liability regime.

Member States transpose that part by 26 July 2028.

Directive (EU) 2025/794 of 14 April 2025.

It postponed the CSRD dates for the second and third waves by two years — to financial years 2027 and 2028 — and the CSDDD’s first application, while the substantive Omnibus I text was negotiated.

Member States had to transpose it by 31 December 2025.

Yes, on conditions.

Article 19a(9) exempts an EU subsidiary included in its parent’s consolidated sustainability reporting where that reporting follows the ESRS or a standard the Commission has determined equivalent, and the parent’s report and assurance opinion are published.

Omnibus I kept that route.

Not under any adopted text.

Omnibus I requires the Commission to assess whether the scope should be extended, including to large undertakings below the new thresholds and to non-EU undertakings without an EU subsidiary or branch, with the report due by 30 April 2031 and every three years after.