In February 2026 the EU adopted the CSRD Omnibus — a major simplification that raised reporting thresholds and paused reporting for early-wave companies. If you export to EU buyers, the headline "fewer companies must report" hides a more important truth: the data demand on suppliers has not gone away. Here's exactly what changed and what to do about it.
Key takeaways
- Directive (EU) 2026/470 entered into force on 18 March 2026, narrowing the CSRD's scope.
- New thresholds: only companies with 1,000+ employees and €450M+ net turnover must report (up from 250 employees / €50M).
- "Stop the clock": Wave 1 companies can be exempted from reporting for financial years 2025 and 2026.
- Large non-EU groups stay in scope above €450M EU turnover (parent) or €200M (EU subsidiary/branch).
- Suppliers still need ESG data: in-scope EU buyers must collect value-chain data — so exporters that can't supply it risk losing contracts.
What is the CSRD Omnibus 2026?
Facing competitiveness concerns, the European Commission proposed the "Omnibus I" package in early 2025 to simplify overlapping sustainability rules. After negotiation, the Council of the EU signed off the final text on 24 February 2026, and it was published in the Official Journal as Directive (EU) 2026/470 on 26 February 2026. It amends both the CSRD and the Corporate Sustainability Due Diligence Directive (CS3D).
The goal was not to abandon sustainability reporting — it was to concentrate the obligation on the largest companies whose impact is greatest, while removing the compliance burden from tens of thousands of mid-sized firms.
What are the new CSRD thresholds after the Omnibus?
| Criterion | Original CSRD (2022) | Omnibus 2026 |
|---|---|---|
| Employees | 250+ | 1,000+ |
| Net turnover | €50M+ | €450M+ |
| Balance sheet | €25M+ | No longer the deciding test |
| Effect | ~50,000 EU companies | Tens of thousands removed from direct scope |
What is the "stop-the-clock" delay?
Many large companies had already started preparing reports under the original timetable. The Omnibus provides a transition: member states may allow these Wave 1 entities that now fall out of scope to skip the 2025 and 2026 financial years. Until each member state transposes this option into national law, Wave 1 entities technically remain subject to existing requirements — so watch your specific country's implementation.
Does the CSRD Omnibus apply to non-EU companies?
| Entity | EU-generated turnover trigger |
|---|---|
| Non-EU parent undertaking | Above €450 million net turnover in the EU |
| EU subsidiary or branch of the group | Above €200 million turnover |
If I'm out of scope, why do I still need ESG data?
This is the crucial nuance the headlines miss. The Omnibus narrows who files a report, but the companies that still file — the largest EU buyers — are precisely the customers that Asian, GCC and other non-EU exporters supply. Under both CSRD and parallel rules like CBAM, those buyers must document Scope 3 and embedded emissions, which live inside your factory data.
In short: your legal obligation may have eased, but your commercial obligation to be ESG-ready is stronger than ever. Suppliers who treat this as "cancelled" risk quietly losing tenders to competitors who arrive with clean, verified data.
Watch: the Omnibus changes in brief
▶ "EU Omnibus Simplification Agenda" — via Compliance & Risks
Your 2026 action plan (in or out of scope)
- Re-test your scope. Recount employees and net turnover against the 1,000 / €450M thresholds. Document the result either way.
- Check national transposition. The Wave 1 "stop-the-clock" option depends on each member state's law — confirm the position in the countries where you operate.
- Build a buyer-ready ESG pack. Baseline your Scope 1, 2 & 3 emissions, energy use and key social metrics so you can answer any customer questionnaire fast.
- Align with CBAM if relevant. If you export steel, aluminium or cement, coordinate this with your CBAM definitive-period preparation — the same emissions data feeds both.
- Get a gap assessment. A short CSRD ESRS quick-scan tells you exactly which data points you're missing before a buyer asks.
Stay contract-ready, whatever the threshold
We run a rapid CSRD scope check, build your buyer-ready ESG data pack, and align it with CBAM — so a customer's sustainability questionnaire is never the reason you lose a deal. Backed by €2.3M PI insurance.
📅 Book a Free 30-Minute CSRD Readiness CallFrequently asked questions
What is the CSRD Omnibus 2026?
An EU simplification law — Directive (EU) 2026/470, in force 18 March 2026 — that narrows CSRD scope by raising thresholds to 1,000+ employees and €450M+ turnover and delaying reporting for Wave 1 companies for the 2025 and 2026 financial years.
What are the new CSRD thresholds?
More than 1,000 employees and above €450 million net turnover, up from 250 employees, €50M turnover and €25M balance sheet under the original directive.
Does it apply to non-EU companies?
Yes for large third-country groups: EU parent turnover above €450M, or an EU subsidiary/branch turnover above €200M. Smaller exporters aren't directly in scope but are still asked for ESG data by in-scope EU buyers.
If I'm out of scope, do I still need ESG data?
In practice yes. Your in-scope EU customers must report value-chain data, so they collect it from suppliers. Exporters without ready ESG data risk losing EU contracts.
What is the "stop-the-clock" directive?
The Omnibus provision letting member states exempt Wave 1 companies (FY2024 reporters) from CSRD for the 2025 and 2026 financial years if they fall outside the revised scope. It postpones rather than cancels reporting.
Sources & further reading
- Council of the EU (Consilium) — "Council signs off simplification of sustainability reporting and due diligence requirements" (24 Feb 2026): consilium.europa.eu
- Norton Rose Fulbright — "European Union adopts Omnibus Directive amending CSRD and CS3D": nortonrosefulbright.com
- DLA Piper — "EU Council approves Omnibus I Directive": dlapiper.com
- Accountancy Europe — "Omnibus explained: key changes to the CSRD and CSDDD": accountancyeurope.eu
This article is general guidance, not legal advice. Member-state transposition varies and rules evolve — verify current obligations against the official EU source and your national regulator before acting.