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    CSRD after the Omnibus: who is in scope, the new thresholds and the reporting timeline

    After the Omnibus I Directive, CSRD applies only to EU companies with more than 1,000 employees and over EUR 450 million net turnover, plus non-EU groups with EUR 450 million EU turnover. Most newly in-scope companies report on financial years starting in 2027, using simplified ESRS, with limited assurance only.

    Last updated 5 November 2026 · By Ella Sustainability Team

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    What did the Omnibus change in CSRD?

    The Omnibus I Directive, Directive (EU) 2026/470, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. It cut the number of companies that must report under the Corporate Sustainability Reporting Directive (CSRD) and lightened what the rest must do. The headline changes are below. Member States have until 19 March 2027 to write them into national law, so check your own country's transposition before you settle your plan.
    What did the Omnibus change in CSRD?
    AreaCSRD after the Omnibus
    Scope for EU companiesMore than 1,000 employees on average and more than EUR 450 million net turnover
    Scope for non-EU groupsMore than EUR 450 million net turnover generated in the EU, plus an EU subsidiary or branch with more than EUR 200 million net turnover
    AssuranceLimited assurance stays; the planned move to reasonable assurance is dropped
    Sector-specific standardsRemoved
    Value chain requestsCapped at the Voluntary Standard for companies with up to 1,000 employees
    Reporting standardsSimplified ESRS adopted by delegated act on 3 July 2026
    Financial holding companiesPure holding companies that do not manage their investments are exempt from direct reporting

    Who is in scope of CSRD now?

    An EU company is in scope when it has more than 1,000 employees on average during the financial year and more than EUR 450 million net turnover. Covington notes that EU intermediate parents assess this on a consolidated basis. A non-EU ultimate parent is in scope when the group generates more than EUR 450 million net turnover in the EU and has an EU subsidiary or branch with more than EUR 200 million net turnover. Companies below these lines are out of mandatory reporting. Many will still be asked for data by customers who are in scope, which is where the value chain cap matters (see below).

    CSRD timeline after the Omnibus

    The dates that matter for planning, taken from the Directive as summarised by Arthur Cox, Covington and Linklaters, and from the simplified ESRS delegated act:
    CSRD timeline after the Omnibus
    DateWhat happens
    26 Feb 2026Omnibus I Directive (EU) 2026/470 published in the Official Journal
    18 Mar 2026Omnibus I enters into force
    3 Jul 2026Commission adopts simplified ESRS, Delegated Regulation (EU) 2026/1463, and the Voluntary Standard
    10 Nov 2026Simplified ESRS enter into force (per Deloitte IAS Plus); early use for FY2026 is allowed from then
    19 Mar 2027Deadline for Member States to transpose the Omnibus changes
    FY starting 1 Jan 2027First reporting year for newly in-scope EU companies; first reports published in 2028
    1 Jul 2027Deadline for harmonised limited assurance standards
    FY starting 2028First reporting year for in-scope non-EU groups; reports due in 2029

    What about wave 1 companies that already reported?

    Companies that reported for 2024 under the original rules are known as wave 1. The Omnibus lets Member States exempt wave 1 companies that now fall below the new thresholds from obligations in the interim years. The exact years depend on national transposition, and the law firm summaries describe them differently, so confirm the position with your auditor or local counsel. Wave 1 companies that remain in scope can use the simplified ESRS for financial year 2026 once the delegated act is in force, or stay on the 2023 ESRS with the Quick Fix and pick selected 2026 options. PwC notes that whichever route you take, you must disclose which version of the ESRS you used.

    What changes in the simplified ESRS?

    The simplified ESRS apply to financial years beginning on or after 1 January 2027. According to Deloitte's IAS Plus summary and PwC, the main changes are: 1. Fewer mandatory disclosures, and optional "may" disclosures removed. 2. A double materiality assessment that can be run top down, starting from your strategy, business model, sectors, geographies and value chain, with a specific assessment only where materiality is not evident. 3. Information based on what is reasonable and supportable without undue cost or effort. 4. A fair presentation requirement for the sustainability statement as a whole. 5. Reliefs for acquisitions and disposals, non-significant activities and partial value chain metrics. The phase-ins below are the ones most companies will use.
    What changes in the simplified ESRS?
    ReliefWho it coversHow long
    Value chain information not availableAll companiesFirst three financial years under CSRD
    Anticipated financial effects (all information)Companies reporting from 2027First two years
    Anticipated financial effects (quantitative)Companies reporting from 2027First four years
    Anticipated financial effectsWave 1 companiesAll information omitted before FY2028; quantitative before FY2030

    The value chain cap and the Voluntary Standard

    The Omnibus stops in-scope companies from asking smaller partners for more than the Voluntary Standard (the former VSME) covers. The cap protects any company in your value chain with an average of 1,000 employees or fewer, and those companies may decline to answer beyond it. It applies to requests made for CSRD reporting. For a large company this changes how supplier data requests should be designed. A long bespoke questionnaire is no longer an option for most of the supply base. You ask for Voluntary Standard datapoints, then fill gaps with estimates and the three-year value chain relief. We covered how to redesign those requests in our blog on the VSME value chain cap.

    Does CSRD apply to UK companies after the Omnibus?

    A UK company has no CSRD duty of its own. Two routes can bring a UK group in. 1. An EU subsidiary that meets the EU thresholds (more than 1,000 employees and EUR 450 million turnover) reports in its own right from financial year 2027. 2. The UK parent reports at group level if the group has more than EUR 450 million EU net turnover and an EU subsidiary or branch above EUR 200 million. Reporting starts with financial years beginning in 2028. UK listed companies should also plan for UK SRS, which the FCA has made comply or explain for periods from 1 January 2027. Much of the climate data overlaps, so one collection process can serve both.

    How to prepare for a first CSRD report in 2028

    If you first report on financial year 2027, your data year has almost started. A workable order: 1. Confirm scope entity by entity, including EU subsidiaries of non-EU groups, once your Member State has transposed. 2. Run a top-down double materiality assessment and document the evidence behind each conclusion. 3. List the datapoints the material topics need and name an owner for each one. 4. Set up collection from those owners now, so the 2027 numbers arrive monthly or quarterly instead of all at once in early 2028. 5. Redesign supplier requests around the Voluntary Standard and decide where you will estimate. 6. Agree the limited assurance approach with your auditor and keep a source on every number.

    Our view: smaller scope, same data problem

    The Omnibus took most mid-sized companies out of CSRD. For the large companies still in it, the reporting got simpler and the data work did not. A top-down materiality assessment saves weeks. It does not get the electricity data for a newly acquired site, or the headcount split for a shared services entity, any faster. In a recent sales call, a sustainability lead at a large services group was halfway through CDP on an extension, with EcoVadis due in December, and the first thing they asked for was automated data collection. That is the pattern we see. The frameworks overlap heavily; the bottleneck is getting numbers out of colleagues across entities with evidence attached. Teams that fix collection once can answer CSRD, UK SRS, CDP and EcoVadis from the same data.

    How Ella helps with CSRD reporting

    Ella is AI-native ESG reporting software, built as an agent for sustainability teams at large and fast-growing companies. It runs the data collection end to end: it sends collect links to data owners, chases them, tracks missing responses, and reads bills, receipts and spend exports dropped into it. Integrations and surveys cover the rest, and every number keeps its source for your auditor. From there Ella builds the CSRD and Voluntary Standard outputs, the Scope 1 to 3 inventory through its carbon module, and the CDP and EcoVadis answers from the same data, with Ella's sustainability team on hand when you need expert support.

    How Ella helps

    ESG reporting software

    Collect, clean and report CSRD and Voluntary Standard data with a source on every number.

    Carbon accounting software

    Build your Scope 1 to 3 inventory for ESRS E1, CDP and SECR with guided boundaries and auto-calculated emissions.

    ESG strategy software

    Turn your double materiality results into targets, actions and a reduction roadmap.

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    Frequently Asked Questions

    What are the new CSRD thresholds after the Omnibus?

    EU companies are in scope when they have more than 1,000 employees on average and more than EUR 450 million net turnover. Non-EU groups are in scope with more than EUR 450 million EU net turnover and an EU subsidiary or branch above EUR 200 million.

    When do companies first report under CSRD after the Omnibus?

    Newly in-scope EU companies report on financial years starting on or after 1 January 2027, with the first reports published in 2028. Non-EU groups start with financial years beginning in 2028, reporting in 2029.

    Does CSRD still apply to companies with fewer than 1,000 employees?

    No, not as a mandatory requirement. They can report voluntarily using the Voluntary Standard, and in-scope customers cannot ask them for more than that standard covers for CSRD purposes.

    Is CSRD reasonable assurance still required?

    No. The Omnibus keeps limited assurance and drops the planned move to reasonable assurance. Harmonised limited assurance standards are due by 1 July 2027.

    What is the CSRD value chain cap?

    It limits what in-scope companies can request from value chain partners with up to 1,000 employees to the datapoints in the Voluntary Standard. Those partners can decline to provide more.

    When do the simplified ESRS apply?

    They apply to financial years beginning on or after 1 January 2027. Companies can use them early for financial year 2026 once the delegated act is in force, which Deloitte puts at 10 November 2026.

    Does CSRD apply to UK companies after the Omnibus?

    Only through an EU subsidiary that meets the EU thresholds, or at group level when the group has more than EUR 450 million EU turnover and an EU subsidiary or branch above EUR 200 million, from financial years beginning in 2028.

    When must Member States transpose the Omnibus CSRD changes?

    By 19 March 2027. Check your own country's law, because some options, such as relief for wave 1 companies that fall out of scope, are left to Member States.

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