Regulation · EU · 2026

CSRD and CSDDD after the Omnibus — what actually changed

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.

● In force
Omnibus I entered into force on 18 March 2026. Member states now transpose the changes into national law. Until your member state acts, first-wave companies should assume existing national CSRD obligations still apply for FY 2025–26.

CSRD — the new scope

CriterionBefore OmnibusAfter Omnibus
EU companiesLarge undertakings meeting 2 of 3: €25m balance sheet, €50m turnover, 250 employeesMore than 1,000 employees AND at least €450m net turnover
Listed SMEsIn scope (wave 3)Out of scope
Non-EU parent companies€150m EU turnover + EU subsidiary/branchMore than €450m EU turnover (2 consecutive years) + EU subsidiary over €200m turnover (or branch)
Sector-specific standardsPlannedRemoved
Value-chain data requestsUncapped in practiceCapped: companies under 1,000 employees can only be asked for information within the voluntary VSME standard
ℹ Transitional reality: first-wave companies (large public-interest entities over 500 employees) remain subject to reporting for financial years 2024–2026 under existing national law, with "Quick Fix" reliefs, unless their member state adopts the optional exemption for companies leaving scope. The new thresholds fully apply from FY 2027.

CSDDD — the new scope and timeline

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.

Out of scope? The requests keep coming anyway

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.

Start with the numbers

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 →

Frequently asked questions

My company has 800 employees. Are we out of CSRD scope now?
Under the Omnibus thresholds, an EU company needs more than 1,000 employees and at least €450m net turnover to be in scope from FY 2027. At 800 employees you would fall outside the mandatory scope. But check two things: whether you were already reporting as a first-wave entity (obligations may continue for FY 2025–26 depending on your member state), and whether large customers will contractually expect VSME-level data regardless.
What is the VSME standard?
The Voluntary Sustainability Reporting Standard for micro, small and medium-sized enterprises, developed by EFRAG. It is a simplified framework that out-of-scope companies can use voluntarily — and it now doubles as the cap on what in-scope companies may demand from suppliers with fewer than 1,000 employees. It includes basic environmental disclosures such as energy use and greenhouse gas emissions.
Did the CSDDD climate transition plan requirement survive?
The final Omnibus text removed the obligation to adopt a climate change mitigation transition plan under the CSDDD. Large companies may still adopt transition plans for other reasons — investor pressure, CSRD reporting where applicable, or national rules — but the CSDDD mandate was dropped.
Does the Omnibus affect CBAM, EmpCo or PPWR?
These are separate instruments and remain in force on their own timelines: CBAM's definitive regime started January 2026, PPWR applies from August 2026, and EmpCo applies from September 2026. A separate Environmental Omnibus proposes simplifications in other areas, but the core obligations of these regulations stand. See our CBAM guide and EmpCo & PPWR guide.
When do the new CSRD thresholds actually bite?
The new scope applies fully from financial year 2027. For FY 2025 and 2026, member states may exempt companies that will leave scope; until such an exemption is transposed nationally, first-wave companies should assume their existing obligations continue, with the Quick Fix reliefs available.
Where can I find the official text?
The Omnibus I Directive is Directive (EU) 2026/470, published in the Official Journal on 26 February 2026, available on EUR-Lex. For compliance decisions, consult a qualified professional — this page is informational only and the transposition picture varies by member state.