The Omnibus I Directive (EU) 2026/470 was published in February 2026 and entered into force on 18 March 2026. It rewrote the scope of both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) — removing roughly 90% of companies from CSRD scope and about 70% from CSDDD. Here is what the new rules say, and why falling out of scope does not mean the data requests stop.
| Criterion | Before Omnibus | After Omnibus |
|---|---|---|
| EU companies | Large undertakings meeting 2 of 3: €25m balance sheet, €50m turnover, 250 employees | More than 1,000 employees AND at least €450m net turnover |
| Listed SMEs | In scope (wave 3) | Out of scope |
| Non-EU parent companies | €150m EU turnover + EU subsidiary/branch | More than €450m EU turnover (2 consecutive years) + EU subsidiary over €200m turnover (or branch) |
| Sector-specific standards | Planned | Removed |
| Value-chain data requests | Uncapped in practice | Capped: companies under 1,000 employees can only be asked for information within the voluntary VSME standard |
The due diligence directive survived, but much reduced. The new thresholds: EU companies with more than 5,000 employees and over €1.5 billion worldwide net turnover; non-EU companies with over €1.5 billion turnover generated in the EU. Transposition is delayed to 26 July 2028, with requirements applying from 26 July 2029.
Substantive obligations were also softened: due diligence focuses on a risk-based approach, liability and penalty provisions were scaled back, and the earlier requirement to adopt and put into effect a climate transition plan was removed in the final text. Fragmentation risk is real — member states retain room for divergent national enforcement rules.
If you supply construction products or materials, the practical question is not whether you must publish a CSRD report. It is whether your large customers — the ones still in scope — will keep asking you for sustainability data. They will, because their own value-chain reporting depends on it.
What changed is the ceiling. Under the Omnibus value-chain cap, in-scope companies can only require suppliers with fewer than 1,000 employees to provide information covered by the VSME voluntary standard — a deliberately lighter set of disclosures that includes basic greenhouse gas figures. That makes VSME the de facto data language between large customers and their smaller suppliers.
For a typical building products manufacturer, three preparations cover most of what will be asked:
1. Basic GHG inventory. Scope 1 and 2 at minimum, ideally with a defensible Scope 3 Category 1 screening for purchased materials.
2. Product-level carbon data. Embodied carbon estimates for key products, moving toward verified EPDs for the ones customers ask about most.
3. A consistent story. The same numbers in customer questionnaires, marketing claims (see EmpCo), and any voluntary reporting — inconsistency is what gets flagged.
FastLCA gives you free embodied carbon estimates for construction materials and a Scope 3 calculator covering Categories 1–6 with DESNZ 2025 factors. Not a reporting platform — a fast way to know your numbers before someone asks for them.
Open Scope 3 calculator → LCA calculator →