Omnibus I: what CSRD looks like after the 2026 changes

The EU Omnibus I package, approved February 24, 2026, materially changes CSRD. If you were planning around the original 2023 directive, several assumptions no longer hold.

What changed

Thresholds tightened

You’re now in scope only if you meet both:

1,000+ employees, AND
€450M+ net annual turnover.

The original directive used 250 employees OR €40M turnover OR €20M assets. The new dual threshold removes ~90% of the originally captured companies — from ~50,000 down to roughly 5,000.

Non-EU companies face €450M EU turnover for parent companies (€200M for EU branches).

Data points cut by 70%

ESRS shrinks from 1,073 mandatory data points to 320. Voluntary data points may still be reported but aren’t required for compliance.

Sector standards dropped

The planned set of sector-specific ESRS standards is eliminated. Only general guidance may follow later.

Assurance stays “limited”

The originally planned escalation from limited to reasonable assurance is abandoned. Limited assurance is what you live with.

Value-chain protections

A “PSME cap”: companies with fewer than 1,000 employees may decline due-diligence information requests beyond the voluntary SME standard. Practically: stop chasing small suppliers for full ESRS data; only ask for what the SME standard covers.

What hasn’t changed

Double materiality is still required.
XBRL tagging is still required.
Limited assurance is still required.
The 11 topical standards (E1–E5, S1–S4, G1) and the cross-cutting general standards still apply — just with fewer data points within them.

Wave-by-wave timing post-Omnibus

Wave	First reporting year	Notes
1	FY 2024 (report 2025)	Already filed; transition exemption for FY 2025 and FY 2026 if you fall below new thresholds
2	Delayed to FY 2027 (report 2028)	Large companies meeting the dual threshold
3	Delayed to FY 2028 (report 2029)	Listed SMEs
4	FY 2027 (report 2028)	Non-EU parents

Member States must transpose Omnibus I into national law by March 19, 2027. National variations are possible — confirm locally.

What to do now

If you’re now out of scope

Confirm your numbers against the dual threshold.
Don’t dismantle your sustainability data collection — investors, customers and supply-chain partners still ask, regardless of legal mandate.
Stay aware of national transposition: a Member State could keep tighter thresholds.

If you stay in scope

Recalibrate the DMA around the 320 mandatory data points.
Optimise your audit strategy for limited assurance (no need to over-prepare for reasonable).
Update supplier engagement: drop ESRS-style requests for suppliers under 1,000 employees, use the voluntary SME standard instead.
If you were already running wave 2, you may benefit from the transition exemption — check.

Omnibus I reflects EU competitiveness priorities. The infrastructure remains; the obligations narrowed. Treat it as a deferral, not a cancellation.