Live explainer, updated 8 Jun 2026

The CSRD Omnibus: what changed

The Omnibus is the EU simplification package that reshaped the CSRD. The final Directive (EU) 2026/470 is now in force: it cut scope by about 80%, removed listed SMEs, delayed reporting by two years and softened assurance. Below we keep the three Omnibus things straight and track what is settled versus still moving. Council of the EU

The Omnibus in five lines

  • Final and in force. Directive (EU) 2026/470, in force 18 March 2026; CSRD transposition due 19 March 2027.
  • Scope cut ~80%. Mandatory CSRD now needs more than 1,000 employees AND more than EUR 450m turnover; listed SMEs are out.
  • Two-year delay. Newly in-scope companies report for FY2027, first reports in 2028.
  • Lighter standards. The revised ESRS cut mandatory datapoints by around 60 to 70% (still in consultation as of June 2026).
  • Assurance softened. The move to reasonable assurance was dropped; limited assurance stays.

Never conflate these

The three Omnibus things

When someone says the Omnibus, they could mean any of three different things. Here is how to tell them apart, and which one actually changed the law.

1. The proposal

Omnibus I proposal

Superseded26 Feb 2025

The European Commission published the Omnibus I package, a set of proposals to simplify CSRD, the CSDDD, the EU Taxonomy and CBAM together, driven by the EU competitiveness agenda. This was a proposal only, not law. It was split into a timing track and a substantive track.

European Parliament Legislative Train

2. Stop-the-clock

Directive (EU) 2025/794

Confirmed lawIn force 17 Apr 2025

The timing track. Published in the Official Journal on 16 April 2025 and in force from 17 April 2025, it postponed CSRD Waves 2 and 3 by two years (and delayed the CSDDD), buying time to negotiate the substance. It did not change thresholds, only timing.

Sidley

3. Final Omnibus

Directive (EU) 2026/470

Confirmed lawIn force 18 Mar 2026

The substantive track. The Council approved the final text on 24 February 2026; it was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. This is the directive that actually changed scope, thresholds, assurance and the value-chain rules. CSRD transposition is due 19 March 2027.

Council of the EU

Live status board

What changed, settled vs pending

Every Omnibus change with its current status. We mark each one plainly so you know what is locked in and what could still shift.

Confirmed lawConfirmed (Dir. 2026/470)

Scope cut ~80% (new thresholds)

The CSRD now applies to EU companies with more than 1,000 employees AND more than EUR 450m net turnover, a cumulative AND test that drops the old two-of-three rule. The Commission estimates this removes about 80% of previously-covered companies, from roughly 50,000 to around 5,000.

BDO

Confirmed lawConfirmed (Dir. 2026/470)

Listed SMEs removed from mandatory scope

The entire former Wave 3 listed-SME category is taken out of mandatory CSRD. Smaller companies instead use the voluntary VSME standard if they choose to report.

PwC Viewpoint

Confirmed lawConfirmed (Dir. 2026/470)

Non-EU thresholds raised

Third-country groups are caught with more than EUR 450m EU net turnover (up from EUR 150m) plus an EU subsidiary that is a large undertaking or an EU branch with more than EUR 200m turnover (up from EUR 40m).

BDO

Confirmed lawConfirmed (stop-the-clock + Dir. 2026/470)

Reporting delayed: FY2027, first reports 2028

The old wave structure is effectively collapsed. Newly in-scope companies report for FY2027, with first reports in 2028; non-EU groups start FY2028, reporting 2029. Wave 1 companies that already report and remain above the thresholds continue. See the full timeline.

DLA Piper

Confirmed lawConfirmed (Dir. 2026/470)

Value-chain cap (trickle-down protection)

In-scope companies may not demand sustainability data beyond the VSME standard from value-chain partners with fewer than 1,000 employees. This shields smaller suppliers from sprawling questionnaires.

Council of the EU

Confirmed lawConfirmed (Dir. 2026/470)

Reasonable assurance dropped

The planned move from limited to reasonable assurance was removed. Limited assurance is now the permanent ceiling, not a transitional step. A common EU assurance standard (aligned with ISSA 5000) is expected around 1 July 2027.

Sidley

In fluxIn consultation, adoption target ~17 Sep 2026

ESRS revision (datapoints cut ~60-70%)

EFRAG delivered technical advice on 3 December 2025; the Commission published a draft revised ESRS delegated act for consultation from 6 May to 3 June 2026. Mandatory datapoints are expected to fall by around 60 to 70%. Adoption is targeted around 17 September 2026, applying from FY2027 (voluntary early use FY2026). Not yet adopted.

European Commission

Confirmed lawConfirmed direction

Sector-specific ESRS scrapped

The originally planned sector-specific ESRS, a major second tranche, have effectively been cancelled under the simplification drive. Watch for any residual voluntary or sectoral guidance.

EFRAG

In fluxDue 19 Mar 2027

National transposition

Member States must transpose the Omnibus CSRD changes by 19 March 2027. Until each country legislates, the precise in-scope population, and the exact penalties, in that jurisdiction remain uncertain.

Covington

In fluxExpected ~mid-2026

VSME delegated act

EFRAG developed the voluntary SME (VSME) standard, adopted as a Commission Recommendation in late 2025. A delegated act formalising VSME, which also defines the value-chain cap, is expected around mid-2026. Pending.

EFRAG

Still in flux

The revised ESRS delegated act, the VSME delegated act, the EU assurance standard and national transposition are not yet finalised as of June 2026. The scope and timeline changes are confirmed law, but the detail of what you report and how it is assured is still settling. We will update this page as each piece lands. Commission consultation

What it means for you

So, do I still have to do this?

Many companies are now out

If you no longer exceed both thresholds, you are out of mandatory scope. You can report voluntarily with VSME, or not at all. Check your status.

Others gained two years

Newly in-scope companies now start with FY2027 (reports in 2028). Use the reprieve to build a defensible double materiality assessment and GHG inventory rather than pausing entirely.

The core work remains

Double materiality, the ESRS and Scope 1, 2 and 3 emissions still apply if you are in scope, and value-chain data requests still flow down.

Changelog

What we changed, and when

This is a living page. Every material edit is logged here.

  • 8 Jun 2026Reviewed after the revised-ESRS consultation closed (3 Jun 2026). Confirmed the ~60-70% datapoint cut and the ~17 Sep 2026 adoption target as still pending.
  • 6 May 2026Added the draft revised ESRS delegated act and its one-month public consultation (6 May to 3 June 2026).
  • 18 Mar 2026Final Omnibus I Directive (EU) 2026/470 entered into force. Updated scope, thresholds, assurance and the value-chain cap to confirmed law.
  • 26 Feb 2026Directive (EU) 2026/470 published in the Official Journal after Council sign-off on 24 February 2026.

This is guidance, not legal advice

This is guidance to help you understand the CSRD Omnibus, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Council of the EU: sign-off of the Omnibus simplification (24 Feb 2026)retrieved 8 Jun 2026
  2. [2]Covington: Omnibus published in the Official Journal; transposition nextretrieved 8 Jun 2026
  3. [3]PwC Viewpoint: the Omnibus directive finalisedretrieved 8 Jun 2026
  4. [4]BDO: CSRD post-Omnibus revised scope and requirementsretrieved 8 Jun 2026
  5. [5]DLA Piper: CSRD amendments under Omnibus I finalisedretrieved 8 Jun 2026
  6. [6]European Parliament Legislative Train: first Omnibus packageretrieved 8 Jun 2026
  7. [7]Sidley: stop-the-clock directive and ESRS simplification processretrieved 8 Jun 2026
  8. [8]European Commission: consultation on revised ESRS (6 May 2026)retrieved 8 Jun 2026
  9. [9]EFRAG: technical advice on simplified ESRS (3 Dec 2025)retrieved 8 Jun 2026

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