Omnibus I amended the thresholds for entities in scope for the CSRD, it will now apply to companies as follows:

• EU undertakings that have during the financial year (on an individual or aggregate basis):
  • an average number of employees exceeding 1000; and
  • a net turnover exceeding €450 million.
• Non-EU Ultimate Parents with a global corporate group that has:
  • a net turnover generated within the EU of more than €450 million in the last two consecutive years; and
  • an EU subsidiary or EU branch generates a net turnover of more than €200 million during the preceding financial year.

Omnibus I also introduced a new financial holding exemption under the CSRD, which exempts certain parent undertakings that operate as financial holding companies and hold a diversified portfolio of investments from the CSRD reporting requirements, subject to certain conditions.

Omnibus I also provides that Wave One companies (those companies which have had to comply with CSRD from financial year starting on or after 1 January 2024) who would no longer fall within the scope of the CSRD should be able to apply an exemption from reporting for financial years beginning between January 2025 and December 2026. However, adoption of the exemption has been left to the discretion of each Member State, meaning that existing Wave One companies with less than 1000 employees and less than €450mn turnover could also still be required to report until FY2027 if Member States do not wish to apply the exemption.¹

• Value chain cap – the revised CSRD recognises that smaller companies, especially SMEs, do not have the capacity to provide the extensive information which is required under CSRD. Therefore undertakings which do not have to report directly under CSRD will be able to decline to provide information to CSRD reporters which is in excess of VSME/VESRS (see below).
• Assurance – the adoption of standards for limited assurance for sustainability information is postponed to 1 July 2027.

Read more here.

In-scope EU companies will need to report in alignment with the European Sustainability Reporting Standards (“ESRS”) which were originally adopted on 31 July 2023 but are currently being amended to reflect the Omnibus I simplifications. The Commission adopted its final version of the revised ESRS on 3 July 2026, which is now subject to a two-month scrutiny period by the European Parliament and the Council (which can be extended by a further two months). Once the scrutiny period is over, the revised ESRS are expected to apply to FY2027 onwards (and Wave One companies have the option to apply the revised ESRS to their reporting for FY2026).

In addition, EFRAG has also developed:

• a Voluntary Sustainability Reporting Standard for non-listed SMEs (“VSME”).
• a Sustainability Reporting Standard for Voluntary Use (“VESRS”) for smaller companies outside the scope of the CSRD but that nonetheless want or need to report sustainability information (this standard is based on VSME). The VESRS introduce a “value chain cap” meaning that smaller companies will not be obliged to provide information beyond that required by the VESRS and they will have the right to decline to provide any such “additional” information.
• reporting standards for non-EU companies not listed on the EU regulated markets that generate net turnover in the Union exceeding EUR 450 million in each of the last two consecutive financial years, and that have either EU branches with net turnover exceeding EUR 200 million in the preceding financial year or are the ultimate parent of EU subsidiaries with net turnover exceeding EUR 200 million in the preceding financial year (previously called “N-ESRS” and “ESRS-TC”, but now known as “ESRS-40a”).

Read more about the revised ESRS, VSME, VESRS and ESRS-40a and their current status in the legislative process here.