CSRD After the Omnibus: Are You Still in Scope?

The Corporate Sustainability Reporting Directive (CSRD) is the EU’s mandatory framework for comprehensive Environmental, Social and Governance (ESG) disclosure. It works alongside the European Sustainability Reporting Standards (ESRS), which set out the detailed reporting requirements, including the topics companies must cover, the metrics they disclose and the methodologies used to assess and report performance.

Since the CSRD came into force, companies have raised concerns about how complex it is and how much work reporting takes. The EU responded with the Omnibus simplification package (Directive (EU) 2026/470), which was adopted on 26 February 2026 and entered into force on 18 March 2026.

The Omnibus I narrows the range of organisations that must report and works alongside a parallel revision that simplifies the ESRS.

For many organisations, the question has changed from “how do we comply?” to “do we still need to comply at all?”

Key developments

 A narrower CSRD scope

Under the revised rules, mandatory CSRD reporting for EU undertakings is focused on the largest companies and groups.

Only companies with more than 1,000 employees and over €450 million in net annual turnover now remain in mandatory scope.

This means many businesses that were previously preparing for CSRD reporting will no longer be subject to the mandatory requirements.

Listed SMEs have been removed from mandatory scope, while companies that were due to begin reporting as part of Wave 2 will only need to report from FY2027 if they meet the revised thresholds.

There is also transitional relief for some Wave 1 companies that began reporting for FY2024 but fall below the new thresholds.

 Non-EU entities are now in scope only where they generate over €450 million net turnover in the EU and have an EU subsidiary or branch generating over €200 million.”

What does this mean for businesses?

The impact will depend on where your organisation sits under the revised scope.

 If you remain in scope

CSRD reporting is still required, but the framework you report against is becoming more streamlined.

Companies should reassess their existing reporting programmes against the revised ESRS rather than continuing with data collection and processes designed around the original requirements.

This may mean fewer datapoints, simpler materiality assessments, changes to value-chain information requests and opportunities to simplify existing reporting processes.

 If you are no longer in scope

Falling outside mandatory CSRD reporting does not necessarily mean sustainability reporting should stop.

Investors, lenders, clients, parent companies and other stakeholders may continue to request sustainability information regardless of whether it is legally required under CSRD.

The question therefore becomes less about simply stopping reporting and more about deciding what information remains useful and proportionate to collect and disclose.

The new voluntary sustainability reporting framework also provides a more proportionate route for organisations outside mandatory scope.

 If you rely on information from your value chain

The Omnibus introduces important protections for smaller businesses within reporting companies’ value chains.

Companies with no more than 1,000 employees can decline CSRD-related requests for information that go beyond what is contained in the voluntary reporting standards.

For larger reporting organisations, this means supplier questionnaires and wider data collection processes may need to be reviewed. For smaller businesses, it creates clearer boundaries around the sustainability information they can be expected to provide for another company’s CSRD reporting.

 A leaner ESRS

The ESRS are being simplified alongside the scope changes:

• November 2025: The European Commission asked EFRAG to streamline the standards, reducing the reporting burden while keeping data comparable and transparent.
• 3 December 2025: EFRAG published its first draft of the simplified ESRS, with fewer datapoints and a streamlined framework.
• 3 July 2026: The Commission adopted the draft delegated act revising ESRS Set 1, together with a Voluntary Sustainability Standard. Together they cut mandatory datapoints by roughly 60%.
• September 2026: The European Parliament and Council’s two-month scrutiny period has ended, and the revised ESRS have now been adopted.

The revised standards:

• simplify the structure of the standards
• significantly reduce the number of required datapoints
• give clearer guidance on materiality assessments
• work better with global frameworks such as ISSB and GRI

 What should businesses do now? 

1. Reassess your scope: Group structures, employee numbers and turnover should be reviewed against the revised thresholds, including the specific requirements applying to EU groups, subsidiaries and non-EU companies. Companies that were preparing as Wave 2 or Wave 3 reports may now have more time or may be out of scope altogether.

1. Track national transposition: Organisations operating across several EU Member States should also continue to monitor national implementation as Member States transpose the Omnibus changes into domestic law by March 2027.
2. Watch the ESRS scrutiny process: Follow the Parliament and Council review of the revised ESRS Set 1, and plan for the final datapoint requirements once they are confirmed.
3. Review your data collection: Pause, reduce or redesign data requests to reflect the smaller datapoint set. This avoids collecting information that is no longer needed.
4. Rethink supply chain requests: The value-chain cap changes what you can ask of smaller partners and what they can reasonably refuse to provide. Supplier questionnaires may need to change.
5. Don’t dismantle your ESG reporting yet: The review clauses could widen the requirements again. Investors, lenders and clients will also keep expecting sustainability data whatever the regulation says. For companies now out of scope, voluntary reporting may still be worthwhile.

How EVORA can help

The Omnibus reduces the number of companies required to report, but it also creates a new set of decisions for businesses: whether they remain in scope, what they now need to report, what information they should continue collecting and how existing reporting programmes should change.

EVORA can help organisations navigate those decisions.

We can assess whether your organisation, group or investee companies remain within the revised CSRD scope and identify the implications for existing reporting programmes.

For companies that remain in scope, we can review reporting requirements against the revised ESRS, identify where data collection and reporting processes can be streamlined, and support materiality assessments, data campaigns, disclosure preparation and reporting readiness.

For organisations that fall outside mandatory scope, we can help determine which elements of sustainability reporting remain valuable based on investor, lender, client and wider stakeholder requirements, and develop a proportionate voluntary reporting approach.

We can also help organisations review value-chain data requests, understand what information can reasonably be requested from smaller businesses and redesign supplier engagement and data collection processes accordingly.

The CSRD has not disappeared, but its scope and reporting requirements have changed substantially. For businesses, now is the time to reassess where you stand and make sure your reporting approach reflects the new framework rather than the rules you originally prepared for.

To understand what the revised CSRD and ESRS mean for your organisation, speak to the EVORA team.