Sector Tracker  ·  03

ESG Reporting

Sustainability reporting and due diligence after Omnibus I — who is now in scope, and what happens to everyone who fell out.

Last updated 1 August 2026  ·  Reviewed weekly

This page is a working record, not a marketing page. Each entry states the instrument, what changed, why it carries commercial consequence and what it requires of the board. Entries are dated and appear newest first. Nothing is removed when it is superseded; it is marked.

The regulatory map

Omnibus I has reshaped the perimeter of both the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive. The thresholds below are the amended ones; the obligation itself has not been diluted for those who remain within them.

DateObligation
16 Dec 2025European Parliament approves the Omnibus I text
24 Feb 2026Council adopts the final text
26 Feb 2026Publication in the Official Journal as Directive (EU) 2026/470
18 Mar 2026Entry into force. CSRD scope narrows to >1,000 employees and >€450m net turnover
2025–2026Transition exemption for wave-one companies that have fallen out of scope
June 2026VSME voluntary standard expected as a delegated act for undertakings outside scope
26 Jul 2028Member State transposition deadline for the amended CSDDD
26 Jul 2029CSDDD rules apply — >5,000 employees and >€1.5bn turnover

Entries

Omnibus I is in force, and roughly four in five previously in-scope companies have fallen out

InstrumentDirective (EU) 2026/470, published in the Official Journal on 26 February 2026, in force 18 March 2026.

The Council adopted the final Omnibus I text on 24 February 2026, following the Parliament's approval on 16 December 2025. CSRD now reaches only undertakings with more than 1,000 employees and net turnover above €450 million. Third-country parents are caught at €450 million of EU turnover where they have a subsidiary above €200 million or a branch meeting the threshold. Listed medium-sized and small companies, and financial holding companies, are out. Wave-one companies falling out of scope receive a transition exemption covering 2025 and 2026.

On the due diligence side the CSDDD threshold rises to 5,000 employees and €1.5 billion. The Article 22 obligation to adopt a climate transition plan is removed entirely. Member States transpose by 26 July 2028 and the rules apply from 26 July 2029. A VSME voluntary standard for undertakings outside scope was expected as a delegated act in June 2026, and is the instrument most likely to become the de facto template for value-chain requests.

Why it matters

Falling out of CSRD scope does not remove the underlying data obligation. In-scope customers, lenders and CBAM declarants continue to demand the same emissions and value-chain data through contract rather than through statute. The obligation migrates from regulator to counterparty — and counterparty obligations carry no phase-in, no transition exemption and no proportionality principle.

Action for the board

Re-run the in-scope test at group level and name the internal owner for data and assurance whichever way it lands. Where you have fallen out, expect the first customer data request within the current contracting cycle, and decide now whether you answer it on the VSME template or on an ad hoc basis.

Covered in OGEMEX Regulatory Monitor No. 001, week ending 31 July 2026.