EU Omnibus package: what changes in the CSRD, ESRS and CSDDD

The Omnibus package is the largest simplification of sustainability rules the European Union has carried out to date. In a sentence: it raises the thresholds and pushes back the deadlines of the CSRD, adjusts the CSDDD and the EU Taxonomy, and takes the large majority of companies out of the direct obligation to report.

An important point to get your bearings: what the Commission called the "Omnibus" in February 2025 was a proposal. As of 2026 it is already law in force. This article sets out what the final version actually says, without speculation.

What is the Omnibus package?

The Omnibus was born as a response to the complexity and overlap of several EU ESG rules, above all the CSRD, the CSDDD and the Taxonomy Regulation. Its stated aim is to reduce the administrative burden and improve the competitiveness of European companies while keeping the objectives of the European Green Deal.

The name deserves a clarification: although it became popular as the "Omnibus Regulation", the piece that reforms the CSRD and the CSDDD is in fact a directive, Directive (EU) 2026/470. The process had two parts:

• "Stop the clock" (Directive (EU) 2025/794): approved and in force since April 2025, it stopped the clock by delaying the application deadlines of the CSRD for companies that had not yet started reporting.
• The substantive Omnibus (Directive (EU) 2026/470): the Council adopted it on 24 February 2026, it was published in the Official Journal of the EU on 26 February 2026 and entered into force on 18 March 2026. This is the one that changes the substance of the obligations. Member States have until March 2027 to transpose it.

Why was simplification necessary?

Before the Omnibus, each directive operated independently and companies often reported redundant information. On top of that, Member States were transposing the CSRD and the CSDDD with different timelines and criteria, which created asymmetries. The Omnibus seeks to harmonise and lighten the load without abandoning the overall sustainability framework.

Main changes to the CSRD

These are the verified changes introduced by the final version:

• A much higher reporting threshold. Only large companies with more than 1,000 employees and more than 450 million euros in annual net turnover remain obliged to report, both criteria at once. Previously, the threshold started at 250 employees.
• Far fewer companies in scope. The Commission estimates that the Omnibus removes around 80% of the companies that were going to be obliged from the CSRD.
• A new timetable. Affected companies will report on financial years starting on or after 1 January 2027, with the first reports in 2028.
• Careful with the first wave. Companies that were already reporting and now fall below the new threshold remain obliged to report the 2025 and 2026 financial years, unless their Member State activates the exemption the directive allows it to introduce. It is not automatic, so check what each country has done.
• No more mandatory extension to listed SMEs. SMEs leave the mandatory scope and may report voluntarily using a simplified standard (VSME).
• Double materiality stays. Despite the simplification, double materiality remains the principle that organises reporting.
• Assurance stays limited. The directive removed the prospect of moving to reasonable assurance in the future. The limited assurance standard must be adopted before 1 July 2027.

The cap on value-chain requests (VSME)

One of the most relevant changes for mid-sized companies is the cap on what their clients can ask of them. A company obliged by the CSRD cannot demand from a company in its value chain with fewer than 1,000 employees more information than that set out in the voluntary standard for SMEs (VSME). This prevents the cascade effect from passing the entire CSRD burden onto suppliers that are not themselves obliged. We develop this in our article on the CSRD for SMEs and the supply chain.

Changes to the ESRS

The Omnibus comes alongside a simplification of the ESRS. The original set ran to more than a thousand data points. Following the draft EFRAG handed the Commission in December 2025, the Commission adopted the delegated act with the revised ESRS on 3 July 2026: it cuts more than 60% of mandatory data points and more than 70% of the total, removes voluntary disclosures and makes the materiality assessment more flexible through a top-down approach. The revised standards apply to financial years starting on or after 1 January 2027, with early adoption possible for 2026. On the same day, a separate delegated act adopted the voluntary standard based on the VSME. Earlier, a "Quick Fix" (July 2025) had already eased the start for the first companies obliged: we explain it in our article on the changes to the ESRS and the Quick Fix.

Changes to the CSDDD (due diligence)

The Corporate Sustainability Due Diligence Directive (CSDDD) is also adjusted:

• Much higher thresholds. Only EU companies with 5,000 or more employees and turnover above 1.5 billion euros remain in scope. Previously it was 1,000 employees and 450 million euros. For third-country companies, the criterion is 1.5 billion euros of EU turnover.
• Later deadlines. Transposition is pushed back to 26 July 2028 and uniform application arrives on 26 July 2029.
• Due diligence focused on the first tier. The analysis concentrates on direct business partners and extends to indirect ones where there is credible evidence of adverse impacts.
• The mandatory climate transition plan is gone. The obligation to adopt and implement a climate transition plan disappears; only the duty to publish remains, from financial years starting on 1 January 2030.
• Civil liability left to national law. The EU-level harmonised civil liability regime is withdrawn; liability is now governed by the law of each Member State.

Implications for companies in Spain

In Spain, the CSRD is transposed through the draft Sustainability Information Act (Ley de Información Empresarial sobre Sostenibilidad), whose definitive approval is not on record as of August 2026. The previous reference rule is Law 11/2018 on non-financial information and diversity, whose 250-employee threshold for the non-financial statement is still in force and should not be confused with the new CSRD threshold. Nor should this be confused with the obligation to calculate the carbon footprint: Royal Decree 214/2025 reinforced that obligation in 2025 for certain companies, a route independent of the CSRD. You can review it in our guide to the carbon footprint registry.

Criticism and debate

The Omnibus has not been free of controversy. Environmental organisations and some investors warn that raising the threshold so far reduces the amount of comparable ESG information available in the market, just as its use to assess risks is growing. On the other side, many companies welcome the administrative relief and the greater clarity. The UN Global Compact has argued that the reform must keep the balance between competitiveness and climate ambition.

How to adapt to the new framework

1. Check whether you are still obliged. Review your headcount and turnover against the new threshold of 1,000 employees and 450 million euros, and if you were in the first wave, confirm what your Member State has decided about the 2025 and 2026 financial years.
2. If you fall out of scope, decide your strategy. Many companies that are no longer obliged choose to keep reporting (with the VSME or another framework) because their clients, banks and investors ask for it.
3. Get your data in order. Whether you report because you have to or voluntarily, the key is having traceable, auditable data. Automated measurement and reporting tools, such as Manglai's, speed up the collection.
4. Communicate transparently. Tell employees, clients and suppliers about your strategy under the new framework.

Frequently asked questions about the Omnibus

Is the Omnibus a regulation or a directive?

The piece that reforms the CSRD and the CSDDD is a directive (Directive (EU) 2026/470), even though it is colloquially called the "Omnibus Regulation". The earlier "stop the clock" was Directive (EU) 2025/794.

When does it apply from?

The substantive directive entered into force on 18 March 2026. The new CSRD thresholds apply to financial years starting on or after 1 January 2027 (first reports in 2028).

Which companies are still obliged to comply with the CSRD?

Large companies with more than 1,000 employees and more than 450 million euros in annual net turnover. The rest fall outside the direct obligation.

If my company reported in the first wave and now falls below the threshold, can it stop reporting straight away?

Not automatically. It remains obliged for the 2025 and 2026 financial years unless its Member State has introduced the exemption the directive provides for.

Does double materiality disappear?

No. Double materiality remains the guiding principle of reporting under the CSRD.

If my company falls out of scope, do I no longer have to report anything?

Not exactly. Your obliged clients may still ask you for data (limited to the VSME standard if you have fewer than 1,000 employees), and many companies keep reporting voluntarily for market reasons. We analyse this in why companies keep their reporting.

If you want to prepare your company for the new framework, at Manglai we help you structure your data and comply with the CSRD in a traceable and efficient way.