Key CSRD Omnibus Changes
While the EU policy objective of enhanced transparency remains unchanged, the practical application of the CSRD has been significantly amended.
Reduced Scope
Under the original CSRD, companies were required to report if they met two out of three criteria: more than 250 employees, over €50 million turnover, or €25 million in total assets. This would have brought a very large number of mid-sized companies into scope.
Following the Omnibus changes, the scope has been substantially reduced. Mandatory CSRD reporting will apply only to companies that:
- have more than 1,000 employees, and
- generate an annual net turnover of more than €450 million.
As a result, the CSRD becomes a framework clearly focused on large enterprises, significantly lowering the number of affected companies across the EU. This applies to EU companies as well as non-EU companies with substantial activity in the EU. For non-EU groups, a turnover threshold of €450 million generated in the EU is expected to determine applicability, although final details depend on the adopted legal text.
Note that sector-specific reporting will become voluntary.
Listed SMEs Fully Exempted
Another major shift concerns listed SMEs. While they were previously included under a lighter reporting regime, the Omnibus package fully removes listed SMEs from the CSRD’s mandatory scope. This represents a clear political decision to shield smaller capital-market actors from disproportionate reporting efforts.
Reporting Timelines: “Stop-the-Clock” in Practice
The Omnibus also affects the reporting timelines of certain companies, taking into account the “stop-the-clock” decision made earlier this year:
- Wave 1 companies (already subject to the Non-Financial Reporting Directive (NFRD)) continue reporting as planned. However, this only affects those with more than 1,000 employees and an annual net turnover of more than €450 million.
- Wave 2 companies will start reporting in 2028, covering financial year 2027. This affects non-NFRD companies with more than 1,000 employees and a net annual turnover of more than €450 million.
- Wave 3 companies will start reporting in 2029, covering financial year 2028. This affects non-EU companies with a net annual turnover of more than €450 million in the EU.
This delay gives companies additional time to prepare internal systems, data processes, and governance structures.
External Assurance and the Role of Subsidiaries
The Parliament also adjusted assurance requirements. The originally planned shift to a reasonable assurance regime has been dropped. Instead:
- limited assurance remains the standard, and
- related assurance standards are expected by October 2026.
In addition, groups benefit from greater flexibility when it comes to acquisitions: newly acquired subsidiaries may be excluded from consolidated sustainability reporting for up to 24 months, easing integration challenges.
Clear Limits on Value Chain Data Requests
Finally, the Omnibus introduces explicit safeguards for smaller suppliers. Companies are no longer allowed to request unlimited sustainability data from smaller value chain partners. Firms with fewer than 1,000 employees will not have to provide information to their bigger business partners beyond what is included in the voluntary reporting standards. To facilitate compliance, the Commission will establish a digital portal with access to templates and guidelines on EU and national reporting requirements.
Key CSDDD Omnibus Changes
The EU’s core ambitions of human rights protection and environmental responsibility along global supply chains remain relevant, but lawmakers have decided to simplify due diligence obligations and reduce the administrative burden on affected companies.
Significantly Higher Thresholds
Under the Omnibus package, the CSDDD will apply only to EU companies with more than 5,000 employees and a net worldwide turnover exceeding €1.5 billion.
For non-EU companies, employee numbers are no longer decisive. Instead, the directive applies if they generate more than €1.5 billion net turnover in the EU.
This firmly positions the CSDDD as a framework targeting only the largest multinational enterprises.
Reduced Due Diligence Scope
The Omnibus also limits the operational reach of due diligence obligations. Instead of covering the full value chain by default companies are now required to focus on:
- their own operations,
- subsidiaries, and
- direct business partners.
A deeper assessment of indirect partners is only required where objective and verifiable information indicates a concrete risk. This marks a clear shift away from blanket value chain coverage to a distinct risk-based approach that directs companies’ efforts toward the most critical areas of their value chain.
Climate Transition Plans Removed
Another key change is the removal of the obligation to adopt and implement climate transition plans under the CSDDD. The topic remains relevant under the CSRD, when considered material, rather than under due diligence law – reducing overlap between the two frameworks.
Delayed Timelines and Adjusted Enforcement
Timelines under the CSDDD are pushed back by one year:
- Transposition into national law is now due by July 26, 2028.
- First application of obligations will begin on July 26, 2029.
Enforcement mechanisms were also softened. Maximum administrative fines are capped at 3% of net worldwide turnover, and plans for a harmonized EU civil liability regime have been abandoned. Civil liability will instead remain governed by national law.
Disclaimer: Information as of December 17, 2025. Subject to change based on future legislative decisions.
