In short
- Omnibus I is a directive. It binds Member States, so it never applies to a company directly. What reaches you is the national law transposing it, due by 19 March 2027.
- It changed your position in one of four ways: you fell out of scope, you stayed in, you gained a statutory right as a supplier, or your non-EU group met a higher threshold.
- Falling out of CSRD does not stop the questions arriving. It changes who is entitled to ask and how much they may ask for.
Strictly, Omnibus I applies to no company at all. Directive (EU) 2026/470 binds Member States to change their law by 19 March 2027, and the thing that will eventually apply to you is that national law. The useful question is what it did to your position, and there are only four answers. You fell out of scope. You stayed in. You never were in, but you supply someone who is, and you have gained a statutory right. Or you are a non-EU group facing a much higher Union turnover bar. Find your box, then act on it.
The test that decides between the first two boxes is short. Since 24 February 2026, Articles 19a(1) and 29a(1) of the Accounting Directive reach undertakings, and parents of groups on a consolidated basis, that exceed both a net turnover of EUR 450,000,000 and an average of 1,000 employees during the financial year. Both limbs, not either. There is no balance sheet criterion anywhere in it.
Which of the four boxes are you in?
Run your consolidated turnover and average headcount against the table. It takes a minute and it decides everything that follows.
| Your situation | What Omnibus I did | Your next move |
|---|---|---|
| Above EUR 450m turnover and above 1,000 employees | Kept you in, from financial years starting 1 January 2027 | Build the ESRS inventory. It has the longest lead time of anything in the file |
| Below either figure, and you reported before | Closed the window. Your last mandatory year is a 2026 financial year at the latest | Confirm your Member State position for 2025 and 2026, then move to voluntary reporting |
| Below 1,000 employees and in a reporter's value chain | Gave you a right to decline requests beyond the voluntary standard | Learn where the ceiling sits and use it |
| Third-country group with Union turnover | Raised the group threshold to EUR 450m and set the EU subsidiary or branch at EUR 200m | Recheck your Union turnover for the last two financial years |
You were in scope and now you are out. When exactly?
For financial years beginning on or after 1 January 2027, subject to your national transposition. That is the clean part of the answer. The messy part concerns the two years before it.
Companies already reporting under the first wave were not let off retrospectively and did not get a stop-the-clock. That wave's window was closed forward instead: Article 5(2)(a) of Directive (EU) 2022/2464 now runs for financial years starting between 1 January 2024 and 31 December 2026. So a 2024 report stands, and a 2026 financial year is potentially still in.
For financial years starting between 1 January 2025 and 31 December 2026, Omnibus I gave Member States an option to exempt undertakings that do not exceed the new figures. An option for the Member State, not an exemption you can claim on your own reading. Whether you had to file for 2025 and 2026 therefore depends on your own country's law, and it is the one question on this page we cannot answer for you.
We will not print a national date. Anyone who does, for any Member State, without pointing at that country's transposing act is guessing.
You stay in scope. What is different for you?
Less than the coverage suggests, and one thing is materially harder.
The reporting duty, the ESRS, the machine readable markup and the limited assurance opinion all survive. Assurance stays limited, and the route to reasonable assurance was deleted rather than deferred, so the step up people were budgeting for in 2028 is not in the text any more. The harmonised limited assurance standards are due from the Commission by 1 July 2027, which means engagements before then run on national standards.
What got harder is value chain data. You still have to report it, and you still have to cover every significant scope 3 category. But a large slice of your supply base can now decline the long questionnaire, which pushes you towards estimation. Where you cannot collect after reasonable effort, ESRS 1 requires you to estimate using reasonable and supportable information such as sector-average data and proxies. Estimation is the rule, not a failure. Building a system that can do it well is the work, and it is what scope 3 consulting is for.
You are a supplier under 1,000 employees. What did you gain?
A statutory ceiling on what a reporting customer may demand of you, and a right to refuse above it.
If you do not exceed an average of 1,000 employees on your balance sheet date and you sit in a reporter's value chain, you are a protected undertaking. You may decline to provide information exceeding the information specified in the voluntary standards, when the request is made for the purpose of sustainability reporting under the directive. Your customer may not require more, and a contract clause saying otherwise is not binding. If they ask beyond the ceiling anyway, they have to tell you which parts exceed the standard and that you may refuse them. They may also rely on your own self-declaration of size without verifying it.
Read the boundaries carefully before you use it. It does not stop you sharing more if you want to. It does not cancel an existing legal or contractual duty to supply something inside the voluntary standard. And it applies only to CSRD reporting requests, so it does nothing about due diligence questionnaires, risk management questions or ordinary procurement scoring. The practical detail is in what a customer may not ask you.
One caution on the ceiling itself. Its content sits in a delegated act, C(2026) 5011, adopted on 3 July 2026 and still in scrutiny on 28 August 2026. The right exists; the exact list of what falls inside it is not final.
You are a non-EU group. Did the third-country regime survive?
Yes, with bigger numbers. Article 40a still applies for financial years starting on or after 1 January 2028.
The group threshold rose from EUR 150 million to EUR 450 million of net turnover generated in the Union in each of the last two consecutive financial years, and the EU subsidiary or branch that has to publish must exceed EUR 200 million of net turnover. If your Union revenue sits between the old and new figures, you have quietly left the regime. If it does not, the 2028 date is unchanged and worth putting in the plan now.
What should you do this quarter?
Two things, whichever box you are in.
First, write your scope conclusion down with the numbers you used and the date you used them. Scope moved twice in eighteen months, and the reason people get this wrong is that they remember a conclusion without remembering which version of the test produced it.
Second, get a repeatable emissions inventory in place regardless. In scope, it is the longest job in the ESRS. Out of scope, it is what your customers and lenders will keep asking for, and the standard to aim at is the voluntary one described in the VSME standard. You can start on a free account on the platform, which serves 5,000+ users, and the full ESRS report is a wider job that CSRD consulting covers.
Set expectations on the first build. A small-business reviewer gave Hedgehog 5 out of 5 on G2 in August 2026 and still said that loading the data is manual and takes effort, and that once it is in, it works well. That first pass is real work whichever side of the threshold you are on.
Sources: Directive (EU) 2026/470 of 24 February 2026, Directive (EU) 2022/2464, Directive 2013/34/EU Articles 19a, 29a and 40a, Delegated Regulation (EU) 2023/2772, and Commission act C(2026) 5011, read against the Official Journal text or the published adopted act. Verified 28 August 2026, re-checked 17 September 2026 with no changes needed. Because 2026/470 is a directive, the date the narrowed scope takes effect in your country is set by that country's transposing law.
Facts on this page were last verified on 2026-09-17.
