- The Omnibus Directive (EU) 2026/470 has been in force since 18 March 2026: from financial year 2027, only companies with more than 1,000 employees AND more than €450m net turnover (both criteria cumulatively) are required to report. Member states must transpose it by 19 March 2027.
- Wave 2 companies above the new thresholds report for the first time for financial year 2027 (reports in 2028). Listed SMEs drop out of scope entirely. Assurance remains permanently at "limited assurance".
- The revised ESRS (Delegated Regulation (EU) 2026/1563) apply mandatorily from financial year 2027 and cut mandatory data points by over 60%; sector-specific standards are removed.
- The Double Materiality Assessment remains mandatory and is the strategic core of CSRD compliance.
- Companies outside the mandatory scope can use the voluntary standard VS (formerly VSME), in force since 24 September 2026 as Delegated Regulation (EU) 2026/1560.
- The EU taxonomy (Delegated Regulation (EU) 2026/73) and the CSDDD (now only more than 5,000 employees and more than €1.5bn turnover, applying from 26 July 2029) were also simplified.
The Corporate Sustainability Reporting Directive (CSRD) represents a milestone in European sustainability reporting. It was introduced to oblige companies to be more transparent with regard to their environmental, social and corporate responsibility (ESG criteria). The aim is to provide investors, stakeholders and the public with comprehensive information on the sustainability performance of companies.
The original development of the European Sustainability Reporting Standards (ESRS) presented companies, especially small and medium-sized enterprises (SMEs), with major challenges due to the comprehensive ESG reporting obligations. In February 2025, the EU Commission therefore made proposals to simplify sustainability reporting obligations with the first Omnibus package, which, in addition to the CSRD, also covers the EU taxonomy and the CSDDD (Corporate Sustainability Due Diligence Directive). The changes have since been adopted and are in force. They are primarily intended to reduce administrative hurdles and facilitate implementation for companies.
In the following, we take a detailed look at the CSRD Omnibus, its most important changes (as of September 2026) and the impact on affected companies.
What is the CSRD Omnibus?
The EU Commission recognized that the original CSRD requirements placed a heavy burden on smaller and medium-sized companies in particular. Against this background, the Omnibus proposal was developed as part of the EU Competitive Compass Initiative. In February 2025, the Commission presented two specific proposals:
- Sustainability Reporting Simplification Proposal: This proposal aimed to reduce the scope of CSRD reporting obligations. Companies with fewer than 1,000 employees were to be exempt, sector-specific standards removed, and the planned switch to "Reasonable Assurance" dropped. The final law added the €450m turnover threshold.
- "Stop-the-Clock" proposal: Companies that already had to report for financial year 2024 (Wave 1) were not affected. Wave 2 and Wave 3 companies received a two-year deferral. This part was already adopted in spring 2025.
Concrete changes under the CSRD Omnibus
With the Omnibus Directive and the revised ESRS, the following changes apply to the CSRD and ESRS:
- Fewer companies in scope: From financial year 2027, only companies with more than 1,000 employees AND more than €450m net turnover are subject to CSRD reporting. Both criteria must be met cumulatively. Whether a company is listed or not is irrelevant. Listed SMEs drop out of scope, and there will be no separate standard for them (LSME).
- Simplified reporting obligations: The revised ESRS (Delegated Regulation (EU) 2026/1563) cut mandatory data points by over 60% and total data points by over 70%.
- Timetable postponed by two years: Companies above the new thresholds that would originally have had to report for the 2025 financial year will now report for the first time for the 2027 financial year.
- Wave 1 companies: Companies already reporting do so for financial years 2025 and 2026 with reliefs ("quick fix", Delegated Regulation (EU) 2025/1416). Member states may exempt Wave 1 companies below the new thresholds for these two financial years. In Germany, this is still open.
- Sector-specific standards removed: There are no additional industry-specific requirements and disclosure obligations.
- Value chain cap: From financial year 2027, companies subject to the CSRD may not request information beyond the voluntary standard VS (formerly VSME) from value-chain partners with up to 1,000 employees. The VS has been in force since 24 September 2026 as Delegated Regulation (EU) 2026/1560. This prevents large companies from passing reporting obligations to smaller value-chain partners unfiltered.
- Audit remains "limited assurance": The originally planned introduction of "Reasonable Assurance" has been removed. Companies still only require "Limited Assurance".
The Omnibus Directive has been in force since 18 March 2026. From financial year 2027, reporting is mandatory only for companies with:
- more than 1,000 employees, AND
- more than €450m net turnover
Both criteria must be met cumulatively. Non-EU parent companies are in scope from financial year 2028 (first report 2029) if they generate more than €450m EU turnover and have an EU subsidiary or branch with more than €200m turnover.
What does NOT change with the CSRD Omnibus?
The Double Materiality Assessment remains mandatory and continues to be a central component of the CSRD. Under the revised ESRS it is simplified, however: the topic list in AR 16 is now only illustrative and a top-down approach is permitted. For efficient implementation of the Materiality Assessment, we recommend our DMA Excel Template, adapted to the revised ESRS, or the Materiality Master Software.
Further Omnibus changes to the EU taxonomy and CSDDD
In addition to the CSRD, the Omnibus package also changed the EU taxonomy and the CSDDD. Here is the final status (September 2026):
EU taxonomy
- New scope: Taxonomy reporting under Article 8 follows the CSRD scope, so it will only apply to companies with more than 1,000 employees and over €450m net turnover.
- Delegated Regulation (EU) 2026/73: in force since 28 January 2026, applying from 1 January 2026. For financial year 2025 there was a one-off option; from financial year 2026 it is mandatory.
- 10% materiality threshold: Non-material activities below this threshold do not have to be assessed in detail.
- Simplified reporting formats: The reporting templates have been cut significantly, which considerably reduces the reporting effort.
Corporate Sustainability Due Diligence Directive (CSDDD)
- Much smaller scope: The CSDDD now only applies to companies with more than 5,000 employees AND more than €1.5bn worldwide turnover.
- Later start: Member states must transpose the directive by 26 July 2028; it applies from 26 July 2029.
- No climate transition plan obligation: The obligation to adopt a climate transition plan has been removed.
- Harmonized liability removed: EU-wide civil liability has been removed; national regulations apply instead.
- Fines capped: Fines are limited to a maximum of 3% of turnover.
These adjustments are intended to reduce the administrative burden and ensure the competitiveness of European companies without jeopardizing the EU's sustainability goals.
When did the CSRD Omnibus changes come into force?
Here is the timeline with the most important dates:
| Date | Event |
|---|---|
| November 2024 | EU Commission President von der Leyen announces the Omnibus legislative package to reduce reporting obligations. |
| January 2025 | The EU publishes the "Competitiveness Compass", confirming the goal of simplification. |
| February 2025 | The European Commission officially presents the first "Simplification Omnibus" package. |
| 28 January 2026 | Simplified taxonomy rules (Delegated Regulation (EU) 2026/73) enter into force. |
| 26 February 2026 | Omnibus Directive (EU) 2026/470 published. |
| 18 March 2026 | Omnibus Directive enters into force (new thresholds: more than 1,000 employees AND more than €450m net turnover, from financial year 2027). |
| 6 May 2026 | Draft of simplified ("revised") ESRS published for public consultation (feedback period until 3 June 2026). |
| 3 July 2026 | Commission adopts the revised ESRS and the VS (formerly VSME). |
| 21 September 2026 | Revised ESRS (Delegated Regulation (EU) 2026/1563) and VS (Delegated Regulation (EU) 2026/1560) published in the EU Official Journal; the VS has applied since 24 September 2026. |
| 10 November 2026 | Revised ESRS enter into force. |
| 1 January 2027 | Revised ESRS mandatory; new CSRD thresholds apply from financial year 2027 (2nd reporting wave). |
| 19 March 2027 | Deadline for EU member states to transpose the Omnibus Directive into national law. |
| 26 July 2029 | CSDDD requirements apply to the remaining very large companies. |
The revised ESRS were adopted on 3 July 2026 and published in the EU Official Journal on 21 September 2026 as Delegated Regulation (EU) 2026/1563. They apply mandatorily to financial years beginning on or after 1 January 2027. For financial year 2026, companies can choose between the original ESRS, the original ESRS with reliefs, or the revised ESRS. Mandatory data points are cut by over 60% and total data points by over 70%. The VS was published at the same time as Delegated Regulation (EU) 2026/1560. Details: Final ESRS and VS standard 2026.
What impact does this have on CSRD implementation in Germany?
The CSRD has not yet been implemented in Germany. Affected companies must therefore continue to comply with the previously applicable Non-Financial Reporting Directive (NFRD), which has been applied in Germany since 2017 with the CSR Directive Implementation Act. Under the NFRD, only capital market-oriented companies with more than 500 employees are obliged to report on sustainability.
Germany's national CSRD transposition law is not yet adopted (as of September 2026). A public hearing took place on 13 April 2026. There is no fixed date for its adoption: according to the federal government (27 August 2026), the further timetable is up to the Bundestag. For reporting year 2025, the CSR-RUG still applies under current law and there is no obligation to apply the ESRS. However, the coalition amendment of 31 March 2026 would apply the new rules retroactively to financial years beginning on or after 1 January 2025; the DRSC and IDW consider this constitutionally questionable.
This means that the NFRD will remain in force for the time being. Once the Omnibus rules have been transposed into German law, companies with over 1,000 employees AND more than €450m net turnover will report in accordance with the revised ESRS from financial year 2027. All other companies can voluntarily apply the voluntary standard VS (formerly VSME). It has been in force since 24 September 2026 as Delegated Regulation (EU) 2026/1560 and is open to all companies not subject to CSRD reporting.
What is the significance of the CSRD Omnibus for companies?
The changes brought about by the CSRD Omnibus have a significant impact on companies in Germany and the EU. While some simplifications are welcomed, companies still need to prepare strategically for the new requirements.
Positive effects of the CSRD Omnibus
- Less bureaucracy: Companies below the new thresholds drop out of the reporting obligation, and the significant reduction in data points lowers the data collection effort.
- More time for implementation: The deadlines for sustainability reporting were extended by two years, giving companies more scope to implement new processes.
- Lower costs for external audits: The requirement for "Reasonable Assurance" no longer applies, meaning that companies can continue to work with less costly audit procedures.
- Less burden from the value chain: The value-chain cap prevents smaller suppliers from being unnecessarily overloaded with reporting requirements.
Challenges posed by the CSRD Omnibus for companies
- Unclear national implementation: Germany has not yet transposed the CSRD into national law. Companies must keep a close eye on which national regulations are introduced.
- Sustainability strategies still required: Even if the reporting obligation no longer applies to some companies, investors, customers and other stakeholders still expect clear ESG data.
- Criticism from stakeholders: Some companies could come under pressure to voluntarily disclose sustainability-related data in order to maintain transparency and credibility.
- Lack of comparability of reports: Voluntary reporting for some companies could lead to a lack of comparability between companies of different sizes.
- Delaying the transformation: Sustainability associations and NGOs criticize that extended deadlines could lead to companies implementing necessary ESG measures more slowly.
What companies should do now
Despite the easing and postponement of CSRD implementation, companies should make good use of the time to prepare for future requirements and optimize their sustainability strategies.
These "No Regret Moves" apply now, especially if CSRD implementation has already begun:
- Clarify responsibilities: Who takes on the key roles in sustainability? Responsibilities and resources should be defined now.
- Conduct or complete a Double Materiality Assessment: The DMA is the core of the CSRD. It is also a strategic tool regardless of regulatory changes. It helps companies assess risks and opportunities and make informed decisions.
- Define a sustainability strategy: A clear sustainability strategy provides orientation and prioritization. Based on the results of the DMA, define specific goals, measures, and KPIs. Think long-term, plan measurably, and anchor sustainability internally and externally. The Materiality Model Canvas can be helpful here.
- Create a voluntary sustainability report: EFRAG published the voluntary, simplified VSME standard in December 2024. As the VS (Voluntary Standard), it has been in force since 24 September 2026 as Delegated Regulation (EU) 2026/1560 and enables companies to report in a pragmatic way. It is ideal for presenting sustainability ambitions to stakeholders.
- Put sustainability goals into practice: Implement the defined measures in the prioritized topic areas. Transparency, clear milestones and continuous monitoring of success are crucial.
Get a ready-to-use Word template for a VS-compliant sustainability report, including a step-by-step guide with tips for filling it in.
Conclusion on the CSRD Omnibus
The CSRD Omnibus brings significant relief for companies: extended deadlines, reduced reporting obligations, and relief for smaller businesses lower the bureaucratic burden. The package has been in force since 18 March 2026. At the same time, sustainable transformation remains a central challenge, as investors, customers, and regulators continue to expect transparency.
Companies should use the time gained to optimize their ESG strategies, make processes more efficient and prepare for upcoming requirements at an early stage. In the long term, sustainable business practices will pay off both in regulatory terms and in terms of market position.
Start your Double Materiality Assessment with our structured Excel template. It guides you through the CSRD-compliant process step by step.
Frequently asked questions about the CSRD Omnibus
Who is still required to report under the new CSRD Omnibus thresholds?
The Omnibus Directive has been in force since 18 March 2026: from financial year 2027, only companies with more than 1,000 employees AND more than €450m net turnover are required to report under the CSRD. Both criteria must be met cumulatively. Non-EU parent companies fall into scope from financial year 2028 if they generate more than €450m EU turnover and have an EU subsidiary or branch with more than €200m turnover.
What is the 'Stop-the-Clock' decision and who does it affect?
"Stop-the-Clock" pushed back reporting deadlines for Wave 2 and Wave 3 companies by two years. Companies that already had to report for 2024 (Wave 1) are not affected. Many Wave 2 companies have since dropped out of scope entirely under the new thresholds (more than 1,000 employees and more than €450m net turnover), and listed SMEs (Wave 3) are no longer in scope at all.
Does the Double Materiality Assessment still apply after the Omnibus?
Yes. The Double Materiality Assessment remains a mandatory core element of the CSRD. It is also a valuable strategic tool regardless of whether your company is in scope, as it helps you identify material risks and opportunities early.
What is the voluntary standard (VS) and who can use it?
The VS (Voluntary Standard) builds on the VSME standard (EFRAG, December 2024). It was adopted on 3 July 2026 and has been in force since 24 September 2026 as Delegated Regulation (EU) 2026/1560. It is open to all companies that are not subject to CSRD reporting. From financial year 2027, CSRD-obligated companies may not require value-chain partners with 1,000 employees or fewer to provide information beyond the VS.
