CSRD After Omnibus: Who's Still In, and What to Say Now

When the EU adopted the Corporate Sustainability Reporting Directive in 2022, it was meant to bring nearly 50,000 companies into standardized sustainability reporting, up from about 11,700 under the rules it replaced. Then the EU simplified it, and the simplification was substantial enough that for most of those companies the practical question is no longer how to comply but what to do with the work already done.

Here's where it stands in November 2026. In short, the CSRD Omnibus, Directive (EU) 2026/470, generally limits mandatory reporting from financial year 2027 to EU companies that exceed both an average of 1,000 employees and €450 million in net turnover, with a separate route for large non-EU groups from 2028.

Key takeaways

• The Omnibus I directive entered into force on March 18, 2026. From financial year 2027, EU companies generally report under CSRD only if they exceed both an average of 1,000 employees and €450 million in net turnover. Member states must write the reporting changes into national law by March 19, 2027.
• The revised European Sustainability Reporting Standards take effect on November 10, 2026 and are mandatory from financial year 2027. By the Commission's count, they cut mandatory datapoints by more than 60% and total datapoints by more than 70%.
• Falling out of scope doesn't end the data requests. From financial year 2027, an in-scope customer can require no more than a short list of datapoints from a value-chain company that averaged 1,000 or fewer employees, for the customer's own CSRD report.

What did the CSRD Omnibus change?

The Omnibus I directive, Directive (EU) 2026/470, got the Council's final approval on February 24, 2026, after the European Parliament voted for it in December. It was published in the Official Journal two days later and entered into force on March 18, 2026. Member states have until March 19, 2027 to write the reporting changes into national law.

The scope narrowed sharply. Before, a large EU company was in if it exceeded two of three size tests: an average of 250 employees, €50 million in net turnover, €25 million on the balance sheet. Listed SMEs had a route of their own. Now a company has to exceed both an average of 1,000 employees and €450 million in net turnover. Listed SMEs are out entirely, and financial holding companies whose subsidiaries run independent businesses can choose not to include sustainability information in their consolidated report.

Most of the later waves fell out. The second wave, large companies that were due to publish their first reports in 2026, was already pushed back two years by the separate "stop-the-clock" directive in April 2025. Those that still meet the new thresholds report for financial year 2027, in 2028. Non-EU groups have a separate route that starts with financial year 2028: more than €450 million in EU turnover in each of the last two financial years, plus an EU subsidiary, or failing that a branch, with more than €200 million in the previous year. Their EU subsidiaries and EU-listed issuers can also have obligations of their own.

Wave one got an exit. These are large public-interest entities, mostly listed companies, banks and insurers, with more than 500 employees on average, whose first CSRD reports covered 2024 and were due in 2025 where national law had put the directive in place. Member states may exempt the ones that fall below the new thresholds for financial years 2025 and 2026.

The standards shrank. The Commission adopted revised European Sustainability Reporting Standards on July 3, and they were published in the Official Journal on September 21. By the Commission's count, they cut mandatory datapoints by more than 60% and total datapoints by more than 70%. The revised standards take effect on November 10 and are mandatory from financial year 2027. A separate voluntary standard, published the same day, is for companies outside the CSRD's scope.

The due diligence rules narrowed too. The main test for EU companies under the Corporate Sustainability Due Diligence Directive is now more than 5,000 employees and more than €1.5 billion in worldwide turnover; non-EU companies are caught by EU turnover above €1.5 billion, with no employee test, and there are separate routes for parent groups and franchising or licensing. The due diligence measures apply from July 26, 2029, and the reporting measures apply for financial years starting on or after January 1, 2030. The directive no longer requires companies to adopt a climate transition plan.

The situation this creates

A large number of companies spent 2023 through 2025 building sustainability data infrastructure, hiring for it, and preparing disclosures. Many of those companies are now out of scope.

That produces three distinct positions, and they need different communications.

Still in scope. The work continues against a materially lighter standard. The reduction in datapoints is real relief, and I'd expect the disclosures that remain to get read more closely, because there's less around them.

Out of scope with the capability built. I think this is the position with the most at stake. You have measurement infrastructure your competitors may not, and no CSRD obligation to publish. Some companies here say they'll keep going: in March 2026, osapiens, which sells reporting software, reported that 90% of respondents at companies removed from CSRD scope planned to maintain or expand their reporting. Its survey covered 403 senior decision-makers at companies with more than 1,000 employees, so it says little about smaller ones. Plans aren't reports, though, and quietly stopping wastes the investment. It also ignores the customers still in scope, who need data from their value chain for their own reports. From financial year 2027, if you averaged 1,000 employees or fewer the year before, the most they can require of you for their CSRD report is a short list of datapoints in an annex to the voluntary standard. This CSRD cap doesn't apply to requests for other purposes, but that list is a practical starting point for what to have ready.

Out of scope and relieved. Fine, and worth being clear internally that regulatory relief isn't the same as stakeholder relief. Customers, investors and procurement teams can still ask for the information, whatever Brussels did to the threshold.

What should a company say if it falls out of CSRD scope?

The tempting move is silence. I think it lands as a retreat, whatever the intent. We've written about the broader version of this, companies doing the work and saying nothing. The CSRD version is sharper because there's a public record to compare against. If a company published sustainability data in 2025 and publishes nothing in 2026, I would explain the gap rather than leave readers to interpret it.

The better move is to keep reporting voluntarily and say why. "We're no longer required to report under CSRD and we're continuing because our customers and investors use this information" is a strong position. Existing systems may reduce the work needed, but data collection, review and publication still need a budget. I think it sets you apart from peers who went quiet and turns a compliance cost into a credibility asset.

The voluntary standard is shorter than full CSRD reporting, which lowers the cost of continuing. Whether it's worth it still depends on whether your customers and investors actually use the information.

What not to do

Don't lead with the CSRD exemption. Framing regulatory relief as good news can read as relief from accountability, whatever the internal reality. If you explain it, pair it with what you'll keep measuring and publishing.

Don't quietly drop the disclosures. Someone comparing your 2025 and 2026 reporting will notice, and the absence invites a worse interpretation than the data would have.

Don't assume the requirement is gone permanently. Member states are still transposing the changes, and as of early September 2026, by Freshfields' count, five still hadn't enacted compliant CSRD laws at all. Ropes & Gray's tracker, published in late October, found that several member states had made progress on, or even completed, Omnibus transposition, while many were still at an early stage. The directive itself requires the Commission to assess, by April 30, 2031, whether the scope should be extended to large companies below the new thresholds, and that assessment can come with a legislative proposal. Before dismantling the measurement capability, I'd weigh what rebuilding it would take if reporting needs change.

Is CSRD still relevant?

CSRD is still relevant, for fewer companies: it remains mandatory for the largest EU companies and, from financial year 2028, for non-EU groups with large EU operations. CSRD's simplification changed the compliance obligation. It didn't stop customers, investors and employees from asking.

My read is that the companies that built sustainability reporting only for compliance face the hardest decision now. The ones that built it because their stakeholders wanted the information have the least to reconsider.

Common questions

What is the CSRD Omnibus? It's the Omnibus I directive, Directive (EU) 2026/470, which narrowed the EU's Corporate Sustainability Reporting Directive and its Corporate Sustainability Due Diligence Directive in early 2026. The CSRD requires in-scope companies to publish standardized sustainability disclosures. The Omnibus raised its size thresholds and removed listed SMEs from scope. The Commission adopted slimmer reporting standards separately.

Who has to report under CSRD after the Omnibus? From financial year 2027, EU companies generally report if they exceed both an average of 1,000 employees and €450 million in net turnover, measured at group level for parent companies, subject to exemptions. Non-EU groups have a separate route from financial year 2028: over €450 million in EU turnover in each of two consecutive years, plus an EU subsidiary or branch above €200 million. Wave-one companies below the thresholds may owe 2025 and 2026 reports unless national law exempts them.

When did the CSRD Omnibus changes take effect? The directive was approved by the Council on February 24, 2026, published in the Official Journal on February 26, and entered into force on March 18, 2026. Member states have until March 19, 2027 to transpose the reporting changes.

How much did the reporting standards change? The revised ESRS, published in the Official Journal on September 21, 2026, cut mandatory datapoints by more than 60% and total datapoints by more than 70%, by the Commission's count. They are mandatory from financial year 2027.

Should companies that fell out of scope keep reporting? Where customers or investors use the information and the cost is justified, I think yes, and the voluntary standard makes continuing cheaper. Check first which reporting duties still apply under national law, and explain any change in what you publish.

Do companies outside CSRD scope still get asked for sustainability data? They can be, by customers that still report. From financial year 2027, if a company averaged 1,000 or fewer employees the year before, the most an in-scope customer can require of it for that customer's CSRD report is a short list of datapoints in an annex to the EU's voluntary standard. This CSRD cap doesn't apply to requests for other purposes.

Sources

• European Parliament and Council, Directive (EU) 2026/470 (Omnibus I) amending the sustainability reporting and due diligence directives, Official Journal of the EU, February 26, 2026
• Council of the EU, Council signs off simplification of sustainability reporting and due diligence requirements to boost EU competitiveness, February 24, 2026
• European Parliament, Simplified sustainability reporting and due diligence rules for businesses, December 16, 2025
• European Parliament, Sustainable economy: Parliament adopts new reporting rules for multinationals, November 10, 2022
• European Parliament and Council, Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive), Official Journal of the EU, December 16, 2022
• European Commission, Delegated Directive (EU) 2023/2775 adjusting the size criteria for undertakings, Official Journal of the EU, December 21, 2023
• European Parliament and Council, Directive (EU) 2025/794 ("stop-the-clock"), Official Journal of the EU, April 16, 2025
• European Commission, Commission adopts revised sustainability reporting standards to reduce administrative burdens for EU businesses while maintaining high-quality disclosures, July 3, 2026
• European Commission, Delegated Regulation (EU) 2026/1563 (revised ESRS), Official Journal of the EU, September 21, 2026
• European Commission, Delegated Regulation (EU) 2026/1560 (voluntary reporting standard), Official Journal of the EU, September 21, 2026
• European Parliament and Council, Directive (EU) 2024/1760 (Corporate Sustainability Due Diligence Directive), consolidated text as of March 18, 2026, EUR-Lex
• osapiens, Why the EU's Omnibus Initiative is not the End of Sustainability Reporting, LinkedIn, March 12, 2026 (survey of 403 senior decision-makers in the UK, DACH, Benelux and France, all at companies with more than 1,000 employees)
• osapiens, Sustainability reporting after the Omnibus: when compliance is no longer the reason to report, May 13, 2026
• Ropes & Gray, CSRD Update – Omnibus Transposition Efforts Continue, With Incremental Progress in September, October 28, 2026
• Freshfields, CSRD, "Stop-the-clock" and Omnibus: Implementation tracker, September 2026

Salient PR advises climate technology and sustainability-focused companies on disclosure communications and earned media. Rule details are from the directives and delegated regulations in the Official Journal of the EU and the Council's, Parliament's and Commission's own announcements, as of November 2026. This post describes the rules; it isn't legal advice.