EU Omnibus Package 2026: Simplifying CSRD Reporting for SMEs & Large Companies

Directive (EU) 2026/470, the "Omnibus I" directive, was published in the Official Journal on 26 February 2026 and has been in force since 18 March 2026. It is settled law, not a proposal, and it amends the CSRD, the Accounting Directive and the CSDDD in a single act. Legal status reviewed on 4 September 2026.

What Directive (EU) 2026/470 Actually Changed

The directive redraws the scope of sustainability reporting rather than postponing it. Around 80 per cent of the companies previously covered by the CSRD fall outside the directive altogether, the wave structure that shaped every implementation plan written before 2026 is gone, and sector-specific ESRS are dropped from the standard set. The adopted text is on EUR-Lex; the revised standards themselves come from EFRAG.

Limited assurance stays. What shrinks is the volume of what gets assured: fewer datapoints, no sector standards, and the Commission still has to adopt the limited assurance standard.

The practical effect is easiest to see in a company that had already started. An automotive supplier with 400 employees in southern Germany had a double materiality analysis, a Scope 1 and 2 inventory and a draft ESRS datapoint list finished by the end of 2025. It is now out of scope, and none of that work is legally required. It is also the only structured environmental dataset the company owns.

Who Must Still Report: Thresholds, Dates and Who Falls Out

Who actually dropped out is worth a number. In my own corpus of 1,401 extracted European sustainability reports, only about one in eight comes from a company with fewer than 1,000 employees. The reporting population was already concentrated at the top. What the directive mainly cancelled was not published reporting practice but the preparation work of companies that had not published yet.

CSDDD: The Due Diligence Changes in the Same Package

The same directive scales the Corporate Sustainability Due Diligence Directive back. Due diligence starts at more than 5,000 employees and more than 1.5 billion euro worldwide net turnover, and for non-EU companies at more than 1.5 billion euro of EU turnover. Member states transpose by 26 July 2028, the rules apply from 26 July 2029, and website disclosure begins with financial years starting 1 January 2030.

Two changes weigh more than the thresholds. Article 22, the obligation to adopt a climate transition plan, is deleted. And member states may not go beyond the directive when they transpose it, so the national-law surprises many companies had budgeted for will not arrive.

The obligation is risk-based rather than exhaustive: due diligence follows where the risk sits, not down every tier of every supplier list. For a mid-sized supplier that changes the source of the pressure without removing it. It now comes from fewer and larger customers, and it arrives through contracts rather than through law.

What the Simplification Saves, and What Is Worth Keeping Anyway

The relief is structural: no sector standards, a reduced datapoint set, assurance limited in both level and volume, and for most previously covered companies no report at all. What disappears is less the report than the machinery around it, data collection across entities, assurance fees, and the internal time to run both.

CSRD compliance is not sustainability. Compliance-first programmes produce conforming reports on thin data, and the real value of sustainability data sits in internal steering. That use case did not change on 18 March 2026. Energy consumption, Scope 1 and 2 emissions, waste and water feed cost decisions, not only disclosures.

There is a second reason to keep measuring. The Voluntary Standard uses a basic module, B1 to B11, that most CSRD preparation work already covers, so carrying data over is a mapping exercise rather than a new data model. The comprehensive module, C1 to C9, is where extra effort would sit, and it is optional.

Five Steps for the 2026 Reporting Cycle

1. Run the scope test. More than 1,000 employees and more than 450 million euro net turnover, both at once, for financial years from 2027. If one leg fails, the CSRD does not apply.
2. Retire what you no longer owe. Sector-specific ESRS preparation and datapoints outside the reduced set can be stopped now instead of maintained in case.
3. Separate report data from steering data. Decide which figures you collected for a disclosure and which ones you actually use to run the business.
4. Map the remainder onto the Voluntary Standard. The basic module is the cheapest home for data that already exists.
5. Fix your position in someone else's value chain. Know what a customer may lawfully request from you and where you can decline, before the next questionnaire arrives.

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