- The CSRD Omnibus has been in force since 18 March 2026. Reporting is now mandatory only for companies with more than 1,000 employees AND more than €450m net turnover (both criteria cumulatively).
- Reporting deadlines for Wave 2 and Wave 3 companies have been pushed back by two years.
- Required data points are reduced by over 60% under the revised ESRS (draft published May 2026); 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), which is being developed from the VSME standard.
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. The EU Commission 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). This is 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 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. The CSRD Omnibus contains two specific proposals:
- Sustainability Reporting Simplification Proposal: This proposal reduces the scope of CSRD reporting obligations. Companies with fewer than 1,000 employees are exempt. Over 60% of mandatory data points are dropped under the revised ESRS, sector-specific standards are removed, and the planned switch to "Reasonable Assurance" is dropped.
- "Stop-the-Clock" proposal: Companies that already had to report for 2024 are not affected by this. All other companies with a reporting obligation receive a deferral of two years.
Concrete proposals of the CSRD Omnibus
The EU Commission proposed the following amendments to the CSRD and ESRS:
- Fewer companies in scope: Only companies with more than 1,000 employees AND more than €450m net turnover are now subject to CSRD reporting. Both criteria must be met cumulatively. Whether a company is listed or not is irrelevant.
- Simplified reporting obligations: The revised ESRS (draft published 6 May 2026) cuts mandatory data points by over 60% and total data points by over 70%. Reporting costs per company are expected to fall by over 30%.
- 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.
- Sector-specific standards removed: There are no additional industry-specific requirements and disclosure obligations.
- Value chain cap: The reporting obligations for suppliers in the value chain are limited to a new voluntary standard (VS), being developed from the VSME standard. 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".
Reporting is now mandatory only for companies with:
- more than 1,000 employees, AND
- more than €450m net turnover
Both criteria must be met cumulatively. For non-EU parent companies, the obligation applies from €450m EU turnover, at the earliest from financial year 2028 (first report 2029).
What does NOT change with the CSRD Omnibus?
The Double Materiality Assessment remains unaffected by the adjustments and continues to be a central component of the CSRD. For efficient implementation of the Materiality Assessment, we recommend our DMA Excel Template or the Materiality Master Software.
Further Omnibus proposals on the EU taxonomy and CSDDD
The Omnibus proposal contains proposals for the CSRD as well as adjustments to the EU taxonomy and the CSDDD.
EU taxonomy
- New thresholds: Only companies with more than 1,000 employees and over €450m turnover must comply with full EU taxonomy reporting.
- Materiality threshold: Companies can omit taxonomy reporting on activities if these account for less than 10% of total revenue, CapEx or OpEx.
- Voluntary reporting simplified: Companies with more than 1,000 employees but less than €450m in turnover (at least €50m) can opt for a simpler reporting system.
- Revision of the DNSH criteria: The rules for the "Do No Significant Harm" (DNSH) principle will be revised, starting with the environmental pollution criteria.
- Operating expenses (OpEx): Companies only have to disclose OpEx if at least 25% of their total turnover comes from taxonomy-eligible activities.
- Simplified reporting formats: Adjustments to the taxonomy, climate and environmental reporting requirements reduce the reporting effort by up to 70%.
Corporate Sustainability Due Diligence Directive (CSDDD)
- Start of implementation postponed by one year: The first mandatory application will not take place until 2028, with only two waves instead of three.
- Scope of responsibility restricted: Due diligence obligations now apply only to direct business partners (Tier 1). Indirect partners need to be checked only if there are concrete indications of violations.
- Harmonized liability removed: EU-wide civil liability has been abolished; national regulations apply instead.
- Fines no longer linked to turnover: The 5% limit of global turnover for fines no longer applies. The amount is now at the discretion of member states.
- No obligation to terminate business relationships: Companies can take alternative measures such as suspension instead of termination.
- Reviews only every 5 years: The obligation to carry out an annual review has been abolished.
- Earlier publication of guidelines: General EU guidelines on CSDDD implementation will be published in July 2026 (six months earlier than planned).
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 proposals 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. |
| 18 March 2026 | The new CSRD thresholds enter into force: more than 1,000 employees AND more than €450m net turnover (both cumulatively). |
| 6 May 2026 | Draft of simplified ("revised") ESRS published for public consultation (feedback period until 3 June 2026). |
| 19 March 2027 | Deadline for EU member states to transpose the CSRD into national law. |
| January 2027 | Extended deadlines for large companies (2nd reporting wave) come into force. |
| July 2028 | First mandatory application of CSDDD requirements for large companies. |
On 6 May 2026, the Commission published a draft of simplified ("revised") ESRS for consultation. Key changes: mandatory data points cut by over 60%, total data points by over 70%, reporting costs per company down by over 30%. The consultation period ran until 3 June 2026. The final delegated act is expected later in 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. Entry into force is expected during 2026 (a public hearing took place on 10 April 2026). For reporting year 2025, there is no obligation to apply the new ESRS unless the law enters into force retroactively.
This means that the NFRD will remain in force for the time being. Once the transposition law is in place, companies with over 1,000 employees AND more than €450m net turnover will report in accordance with the revised ESRS. All other companies can voluntarily apply the simplified voluntary standard (VS), which is being developed from the VSME standard (EFRAG, December 2024).
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 with fewer than 1,000 employees may be exempt from the reporting obligation, and the significant reduction in data points lowers the data collection effort.
- More time for implementation: The deadlines for sustainability reporting will be 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 has published a voluntary, simplified standard (VSME, being broadened into the "VS" Voluntary Standard) that 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 VSME-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. 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?
Since 18 March 2026, 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 €450m EU turnover, at the earliest for financial year 2028.
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 and Wave 3 companies have also dropped out of scope entirely under the new 1,000-employee threshold.
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) is being developed from the VSME standard (EFRAG, December 2024) into a broader standard. It is relevant for non-SMEs with fewer than 1,000 employees (or under €450m turnover) that fall outside the mandatory CSRD scope. CSRD-obligated companies may not require value-chain partners with 1,000 employees or fewer to provide information beyond the VS.
