The Corporate Sustainability Reporting Directive (CSRD) is the EU’s framework for mandatory sustainability reporting. It requires in-scope companies to report on environmental, social, and governance matters as part of their management reports. Reporting follows the European Sustainability Reporting Standards (ESRS) adopted by the European Commission.
What Omnibus I changed
On March 18, 2026, the Omnibus I Directive entered into force, significantly narrowing the CSRD’s scope. The key changes are:
Higher thresholds: CSRD now applies only to companies with more than 1,000 employees and €450 million net turnover. The original thresholds (250 employees / €40m turnover) no longer apply.
Listed SMEs removed: listed small and medium-sized enterprises are no longer in scope.
Value chain cap: companies cannot request sustainability data from supply chain partners that fall below the revised thresholds.
Simplified ESRS: the European Commission must adopt simplified reporting standards within six months of entry into force (i.e. by September 2026).
Transposition deadline: Member States have until March 19, 2027 to transpose the revised rules. The new thresholds apply from financial years starting January 1, 2027.
Until transposition of Omnibus I is complete, CSRD reporting obligations apply only in Member States that have already transposed the original directive. In practice, this currently affects large listed companies and regulated financial institutions in those jurisdictions.
Transposition status
Member States were required to transpose the original CSRD by July 6, 2024. Most missed this deadline. The Stop-the-Clock Directive subsequently required Member States to implement the revised timetable by December 31, 2025. Although many Member States have now adopted implementing legislation, not all jurisdictions have completed the transposition process and national approaches continue to evolve. The European Commission opened infringement proceedings against late transposers in September 2024. Variations in national implementation may create compliance challenges for companies operating in multiple jurisdictions.
Timeline
January 5, 2023: CSRD entered into force.
January 1, 2024: Wave 1 – large public-interest entities with over 500 employees (already subject to the Non-Financial Reporting Directive (NRFD)) began reporting under CSRD. First reports covered FY2024 and were due in 2025.
July 6, 2024: Original deadline for Member States to transpose the CSRD. Most Member States missed this deadline.
April 17, 2025: Stop-the-Clock Directive entered into force, postponing Wave 2 and Wave 3 application dates.
December 31, 2025: Deadline for Member States to transpose the Stop-the-Clock Directive.
March 18, 2026: Omnibus I Directive entered into force. CSRD scope narrowed to companies with more than 1,000 employees and €450 million net turnover. Listed SMEs removed.
March 19, 2027: Deadline for Member States to transpose Omnibus I. Revised thresholds apply from financial years starting January 1, 2027.
2028: First reports under the revised Omnibus I scope, covering FY2027.
How we can help
Our global Sustainability and ESG team advises on CSRD readiness, ESRS implementation, double materiality assessments, and the interaction between CSRD and the EU Taxonomy. We help companies assess whether they remain in scope under the revised Omnibus I thresholds. We also advise on national transposition differences across jurisdictions.
Further reading
EU: Corporate Sustainability Reporting Directive
EU: Corporate Sustainability Reporting Directive: sustainability reporting standards include new worker transparency duties
Key contacts
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