EU Omnibus explained: what applies since 2026

What is the Omnibus I package?

Omnibus I is the EU's simplification package for sustainability rules. The Commission proposed it in February 2025. It arrived in two steps: first, Directive (EU) 2025/794 ("stop the clock", in force since Apr 17, 2025) delayed two reporting waves by 2 years. The substantive reform followed. It has been in force since Mar 18, 2026 as Directive (EU) 2026/470 — so it is law, not a proposal.

Who has to report under the CSRD?

Scope is two-stage. Which rule applies to you depends on the financial year — the single most common misunderstanding on this topic.

• Financial years through 2026: large public-interest entities with more than 500 employees keep reporting as before
• Financial years from 2027: only companies with more than 1,000 employees and more than EUR 450m net turnover — both criteria must be met
• Member States may exempt companies that do not exceed both thresholds from 2027 from the reporting duty for financial years starting in 2025 or 2026
• Austria has used this option: under § 908(2a) UGB, only public-interest entities above both thresholds report under the new rules. The other previously covered entities apply the earlier law under § 908(2b) UGB (non-financial statement) or report voluntarily under the new rules
• The former "two of three criteria" test (balance sheet, turnover, headcount) no longer determines CSRD scope

What was cut

Omnibus I narrows not only who reports but also what they report.

• Sector-specific ESRS are gone entirely — cancelled, not postponed
• The planned move from limited to reasonable assurance was dropped; limited assurance stays
• Listed SMEs fall out of mandatory scope and may report voluntarily
• The ESRS themselves were slimmed down by Delegated Regulation (EU) 2026/1563, which applies to financial years from 2027; for financial years starting in 2026, entities that already report may choose the previous or the revised set

What changes for the CSDDD

Supply-chain due diligence was relieved even more sharply. Thresholds rise to more than 5,000 employees and more than EUR 1.5bn net turnover. It applies from Jul 26, 2029.

• The climate transition plan duty (Article 22) was deleted — only the disclosure of an existing plan under ESRS E1-1 remains
• The EU-wide civil liability regime was repealed; the right to compensation remains where national law already provides for it
• Fines are capped at 3% of worldwide net turnover
• The due diligence duties themselves remain, with risk-based prioritisation

EU Taxonomy and CBAM

Both were eased, but through their own legal acts — not through the Omnibus directive itself.

• EU Taxonomy: companies leaving CSRD scope are generally relieved of the Taxonomy duty too. They may still report voluntarily; the directive contains no separate opt-in rule
• Delegated Regulation (EU) 2026/73 allows non-financial undertakings to skip the eligibility and alignment assessment for activities whose cumulative share is below 10% of the denominator of the relevant KPI
• CBAM: Regulation (EU) 2025/2083 exempts importers below 50 tonnes of net mass per calendar year, aggregated across all commodity codes. Electricity and hydrogen are excluded from the exemption

What does this mean for your company?

Leaving scope does not mean you stop needing ESG data. The pressure moves from the reporting duty to the supply chain.

• Large customers, banks and investors keep asking for ESG data, regardless of who is legally obliged
• There is a cap to lean on: under Delegated Regulation (EU) 2026/1560, a CSRD reporter may require, for its CSRD reporting, only the datapoints in Annex II of that regulation from a company with at most 1,000 employees. It applies to financial years from 2027; requests based on other obligations are not affected. In addition, these companies may refuse requests going beyond that for CSRD purposes; contract terms to the contrary are void. If the reporting company still asks for more, it must say which information goes beyond the cap and that it may be refused. Member States transpose this right by Mar 19, 2027. Austria already introduced such a cap with the NaBeG (§ 243ba UGB, since Feb 19, 2026; there the benchmark is Annex I of Recommendation (EU) 2025/1710)
• A GHG inventory helps with customer requests, reduction targets, product footprints and — if you import CBAM goods — emissions data
• Build the data structure now and you report by choice instead of answering under pressure