CSRD Omnibus: definition, content and practical implications for businesses

For a comprehensive overview of the CSRD, its objectives and scope, see our dedicated article: CSRD – obligations, timetable and impacts for businesses.

Omnibus CSRD: what exactly are we talking about?

A simplification package, not a challenge to the CSRD

With the adoption of the omnibus package, sustainability reporting is not dead.

However, it has been streamlined:

• fewer companies will be required to produce a CSRD report from 2028 onwards.

• ESRS standards will be less dense.

• auditing will remain limited.

On the contrary, companies that are not subject to the obligation to report their ESG data will be able to "protect" themselves from overly restrictive reporting requirements. The omnibus package introduces technical and political adjustments.

Why did the European Commission launch the CSRD omnibus?

In January 2025, the European executive unveiled its Compass for Competitiveness, in other words its economic programme for the coming years. It is based on the conclusions of the report on "the future of European competitiveness" by former Italian Prime Minister Mario Draghi, also former President of the European Central Bank (ECB). One section of this document was dedicated to simplifying EU rules to reduce the administrative burden on businesses. The sustainability report was mentioned in this section.

On 26 February 2025, the European Commission presented its "first two omnibus packages" to "make sustainability reporting more accessible and effective". The stated objective was also to exclude listed SMEs from the scheme.

The omnibus process spanned the whole of 2025, with multiple rounds of discussions between EU bodies (EFRAG, European Commission, European Parliament, Council of the EU, etc.) and consultations with businesses and NGOs. At the end of 2025, the process came to an end with the adoption of all the texts constituting the omnibus package by the co-legislators.

Omnibus CSRD, ESRS, Taxonomy: what is involved?

The omnibus package introduces changes to the legal requirements for sustainability reporting (CSRD Directive, Accounting and Audit Directive), the standards on which the reporting is based (ESRS in particular) and the texts implementing the EU green taxonomy (delegated acts, for example).

What the CSRD omnibus changes

Reduced scope: which companies are still affected?

With the omnibus, the CSRD refocuses on very large companies and clarifies the voluntary reporting requirements for SMEs and mid-cap companies.

Only companies or groups with net turnover exceeding €450 million – on an individual or consolidated basis – and employing an average of more than 1,000 employees during the financial year – at group level where applicable – will be required to produce a sustainability report from 2028 onwards (report for the 2027 financial year).

So-called wave 1 companies, currently subject to the regulation – listed companies or groups with more than 500 employees and a net turnover of more than €50 million and/or a total balance sheet of more than €25 million – will have to continue their reporting work in 2026 and 2027. Unless they benefit from an exemption that may be implemented by Member States because they do not exceed the thresholds presented above (pending transposition of the package into national law).

Large unlisted companies (wave 2) will only be affected from 2028 onwards if they exceed the new thresholds. Conversely, listed SMEs are now definitively excluded from the CSRD regime.

Case of financial holding companies

Financial holding companies will be eligible for an exemption. They may not have to submit a consolidated sustainability report in certain cases. This option is now provided for in the new version of the legal texts on sustainability reporting resulting from the omnibus package.

Reducing pressure on SMEs and the value chain

The principle known as the "value chain cap" limits the amount of information that a company subject to sustainability reporting can collect from companies that are not subject to reporting because they are protected.

The former cannot request more information than that identified in the future standard established for voluntary reporting, except:

• if this information is exchanged voluntarily, for example because it is commonly shared within a sector of activity,

• if the request for information is made on a legal basis (to ensure due diligence, among other things).

Any contractual clause contrary to this principle shall be considered null and void.

Rights of protected companies

In response to a request from a client, protected companies – companies that are part of the value chain of a company subject to sustainability reporting and have fewer than 1,000 employees – have the right to refuse to provide information beyond that presented in the voluntary standard.

They may self-declare as "protected companies". They will benefit from the future standard on voluntary reporting, which will be adopted via a delegated act of the European Commission no later than four months after the entry into force of the last omnibus text adopted.

Revision of the ESRS: towards fewer data points

Following the adoption of the omnibus package, the European Sustainability Reporting Standards (ESRS) are being revised to:

• avoid imposing a disproportionate administrative or financial burden on companies.

• give priority, as far as possible, to the presentation of quantitative information in the report.

This review is currently underway. A new delegated act is expected to be published by the European Commission by the end of June 2026. These revised ESRS (or ESRS "Set 2") will be based on the work of the EFRAG submitted to the European Commission at the end of 2025.

For companies currently subject to sustainability reporting (to be submitted in 2026), the European Commission made an initial amendment to the ESRS standards via a delegated act known as a "quick fix" in July 2025. These revised standards maintain exemptions from data to be provided in sustainability reports until 2027.

Schedule adjustments: "stop-the-clock" text

The omnibus package consists of an initial text published in April 2025 entitled "stop the clock". It froze in time the companies subject to the obligation to submit a sustainability report and to the duty of vigilance.

In other words, under this text:

• only wave 1 companies had to continue their reporting work.

• those in subsequent waves could wait until 2028 at the earliest.

Now, with the adoption of the second omnibus package, which establishes a single threshold for EU companies, as outlined above, the adjustments resulting from the "stop the clock" text no longer have any legal substance.

What the CSRD omnibus does not change

The logic of double materiality remains central

The principle of double materiality remains enshrined in EU law requiring the production of a sustainability report. Reporting must be carried out via a double materiality analysis based on:

• the company's impact on the environment and society in general (impact materiality).

• the impacts of environmental, social and governance issues on the company's financial performance (financial materiality).

  The requirement for reliability and auditability remains

  The post-Omnibus Package sustainability report must still be audited and certified by an authorised third party. The independent assurance service provider – auditor or independent third-party body – certifies the report considering a limited level of assurance. Reasonable assurance is no longer required. The level is determined by considering the double materiality analysis carried out, compliance with ESRS standards, data reliability, etc.

  Climate remains a key pillar (ESRS E1) of European standards

  With the omnibus package, the ESRS standards are currently being revised. However, the climate standard (ESRS E1), with its key principles, will remain in the new version of the ESRS. It should be noted that it was identified as material by 98% of companies that produced a first sustainability report in 2025. Even though ESRS E1 is expected to contain fewer data points and some relaxations, it will continue to be based on the presentation of a climate transition plan, identified climate risks, the company's resilience to these risks, its policies, actions, targets and indicators in place, and the anticipated financial effects.

  Post-omnibus CSRD: what are the practical implications for companies?

  For companies that remain within the scope

  For companies that remain within the scope of the CSRD after the omnibus, the level of requirements remains high and more transparent.

  The reduction in scope does not mean a reduction in substance, but rather a clarification of expectations in terms of:

  • data quality.

  • robust analysis of double materiality.

  • transparency on climate trajectories and ESG risks.

  Authorities, investors and stakeholders will expect more structured, consistent and actionable reporting for decision-making.

  In this context, the omnibus offers an opportunity to better prioritise efforts rather than reduce them. Companies can thus:

• focus their resources on truly material issues.

• strengthen the governance of non-financial data.

• structure sustainable processes rather than one-off responses to the regulatory calendar.

  When used effectively, this phase enables the CSRD to be leveraged for internal structuring (roles, responsibilities, tools, controls) rather than simply as an annual compliance exercise.

  For companies outside the mandatory scope

  For companies that fall outside the scope of the CSRD, the removal of the direct obligation does not mean that all pressure has disappeared.

  Large groups, public and private contractors, and financiers will continue to request structured information to meet their own reporting and risk management obligations.

  In this context, voluntary reporting, aligned as closely as possible with the CSRD/ESRS approach, becomes a strategic asset. It enables companies to:

• respond to customer requests in a standardised manner.

• improve credibility with banks and investors.

• differentiate themselves in the markets.

  For these companies, the challenge is less about replicating all the requirements than adopting an approach focused on the main material issues and indicators expected by the ecosystem.

  For multi-entity groups and organisations

  Multi-entity groups face the complex task of managing subsidiaries of varying sizes, ESG maturity and regulatory constraints. It is crucial to define clear consolidation principles, common standards and a harmonised set of indicators to avoid fragmented, costly and difficult-to-use reporting.

  These trade-offs must consider local capabilities, materiality issues and the group's overall sustainability strategy.

  Conclusion — The CSRD omnibus: simplification, not relaxation

  The omnibus simplifies the scope and certain provisions but should not be interpreted as a sign of relaxation.

  Fewer companies are formally affected, but those that remain face clearer, more structured expectations without any reduction in the quality and usefulness of the information published.

  In this landscape, the CSRD remains a benchmark for organising sustainability governance, structuring non-financial data and engaging with stakeholders.

  Organisations that invest now in robust tools and methods will gain a sustainable competitive advantage by transforming regulatory constraints into strategic leverage.

  Frequently Asked Questions

  What exactly is the CSRD Omnibus?

  The CSRD Omnibus refers to a package of legislative proposals from the European Commission, adopted by co-legislators – MEPs and representatives of EU Member States – aimed at simplifying the implementation of the CSRD without undermining its fundamental principles. It seeks to reduce administrative complexity, limit the indirect effects on SMEs and improve the clarity of reporting, while maintaining ESG transparency requirements for large groups.

  Why did the European Commission launch the CSRD omnibus?

  The CSRD has prompted numerous responses from the field: heavy workload, high volume of ESRS data, difficulties for less mature companies and pressure on SMEs in the value chain. The omnibus aims to make the system more proportionate, preserve European competitiveness and promote greater acceptance of the regulatory framework.

  Does the omnibus call into question the CSRD's climate objectives?

  No. The omnibus does not call into question the CSRD's climate objectives. Climate-related requirements, particularly those set out in ESRS E1 (emissions, decarbonisation trajectories, transition plans), remain central. The adjustments mainly concern the scope, timetable and volume of data expected, not the underlying environmental ambition.

  Which companies remain affected by the CSRD after the omnibus bill?

  The omnibus package refocuses the CSRD on the largest companies, i.e. those with more than 1,000 employees and a turnover of more than €450 million. Many companies that were previously subject to the CSRD (including those in waves 2 and 3 in particular) are no longer within the mandatory scope, but remain exposed to indirect requirements via their customers, investors, financial partners and their sector of activity.

  Can companies that are no longer subject to CSRD requirements ignore ESG reporting?

  No. Even outside the mandatory scope, companies continue to be asked to provide ESG data, particularly in the context of customer-supplier relationships, financing or tenders. The omnibus encourages the use of simplified voluntary standards to meet these expectations without bearing the full burden of the CSRD. An EU-wide portal will be set up with guidelines, templates and other tools to help all types of companies understand the CSRD and its expectations.

  Does the omnibus change the CSRD implementation timetable?

  Yes, by creating a single level of thresholds for EU companies from 2028 onwards. Waves 1, 2 and 3 will eventually disappear. The implementation timetable for third-country companies (parent companies) remains unchanged, but the applicability thresholds have been modified.

  Should the CSRD roadmap be revised following the Omnibus?

  No, for companies that remain affected, despite the period for transposing the latest text into Member State law, which is about to begin (one year). The Omnibus is an opportunity to prioritise truly material issues, clarify data governance and adapt the scope of reporting to efficient data. Companies that anticipate the new ESRS and structure their approach now will gain in robustness, credibility and ability to meet regulatory and financial expectations in the medium term.