The CSRD also introduces harmonized European standards (European Sustainability Reporting Standards – ESRS) to promote transparency and comparability of ESG information.

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CURRENT REGULATORY FRAMEWORK (post-Omnibus)

updated 26/02/2026

 

In February 2026, Directive (EU) 2026/470 was adopted as part of the regulatory simplification package known as “Omnibus I” which also affects sustainability reporting under the CSRD.

The Directive was published in the Official Journal of the European Union on 26 February 2026 and enters into force on 18 March 2026, pursuant to its final provisions.

Member States have 12 months from the entry into force to transpose the amendments into national law, with specific exceptions provided for in the Directive.

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Who must report now:

➡️ EU companies
Companies employing more than 1,000 employees and with annual net turnover exceeding €450 million.

➡️ Non-EU parent companies
Non-EU companies generating more than €450 million turnover in the European Union and operating a significant subsidiary or branch in the Union, according to the size criteria established by the Directive.

🚫 Listed SMEs are exempt from the obligation, as are companies that do not exceed the thresholds mentioned above.

This new setup significantly reduces the number of companies affected compared to the original scope of Directive (EU) 2022/2464.
 

Reporting timelines:

 

➡️ Companies already subject to NFRD
First report for FY 2024, to be published in 2025

➡️ Other companies meeting the new EU criteria
First report for FY 2027, to be published in 2028
 

⚠️ Final deadlines will depend on the national transposition of Directive (EU) 2026/470 and may be subject to further adjustments.

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BEFORE THE CHANGES (original CSRD scope)

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Before Omnibus I, the CSRD provided for a progressive application of the reporting obligation based on broader size criteria:

 

1. Significant public interest companies already subject to NFRD:

> Report in 2025 (on the financial year 2024)

 

2. Large unlisted companies which exceed at least two of the following criteria:

• Average number of employees: 250

• € 25 million balance sheet

• € 50 million in net turnover

> Report in 2026 (on the financial year 2025)

 

3. Small and medium listed enterprises (excluding microenterprises), small and non-complex credit institutions and captive insurance companies:

>Report in 2027 (on financial year 2026)

 

4. Enterprises and branches of subsidiaries with parent company outside the EU, where the parent company generated net turnover in the EU exceeding 150 million Euro for each of the past two consecutive financial years and at least:

• one subsidiary satisfies the size requirements set out in the CSRD and/or

• one branch has generated net turnover exceeding 40 million Euro for the previous fiscal year

>Report in 2029 (on financial year 2028)

 

⚠️ This original setup (no longer in force) would have included a much larger number of companies compared to the post-Omnibus framework.​

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STATUS OF ESRS

The CSRD introduced the European Sustainability Reporting Standards (ESRS), which define the content and structure of ESG information to be reported. The ESRS have been adopted by the European Commission and constitute mandatory standards for companies subject to CSRD.

Following the Omnibus I simplification package, EFRAG has prepared draft simplified ESRS aimed at reducing the number of data points and improving proportionality of the information required, particularly for companies close to the minimum size thresholds.

The final version of the simplified ESRS, their content, and official application date will be determined through subsequent acts by the European Commission.

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DISCLAIMER​

The European sustainability reporting framework is continuously evolving: the final version of the CSRD, as amended by Omnibus I, must be transposed into national law and may be subject to further delegated acts and implementing measures. For correct and up-to-date interpretation of the applicable rules, it is always recommended to refer to the official texts published in the Official Journal of the European Union and to the guidance of the competent national authorities.

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