In short
- The next date is the start of your first financial year on or after 1 January 2027. Transposition into national law is due by 19 March 2027, which is after it.
- Three deadlines in circulation no longer exist: 30 June 2026 for sector ESRS, 1 October 2026 for assurance standards, and 1 October 2028 for reasonable assurance.
- The delegated acts adopted on 3 July 2026 had no entry-into-force date at all on 28 August 2026. One of them still carried a placeholder in its own text.
The next Omnibus I date that matters is the first day of your first financial year beginning on or after 1 January 2027, because that is when the narrowed scope starts to apply. National transposition is due by 19 March 2027, which falls after it. Three deadlines people still plan around were deleted or moved: 30 June 2026 for sector-specific standards, 1 October 2026 for assurance standards, and 1 October 2028 for reasonable assurance. What has to be true by 1 January 2027: you know, with the numbers written down, whether you exceed both EUR 450 million of net turnover and 1,000 employees.
Everything below comes from Directive (EU) 2026/470 and the two directives it amends, read against the Official Journal on 28 August 2026.
What is the full Omnibus I calendar?
Nine dates, three of them behind us.
| Date | What happens | Status on 28 August 2026 |
|---|---|---|
| 24 February 2026 | Directive (EU) 2026/470 adopted | Done |
| 26 February 2026 | Published in the Official Journal | Done |
| 18 March 2026 | Enters into force, on the twentieth day after publication | Done |
| 31 December 2026 | End of the window for the first reporting wave under Article 5(2)(a) | Ahead |
| 1 January 2027 | Financial years starting on or after this date are the first under the revised scope | Ahead, and it is the one that matters |
| 19 March 2027 | Member States must transpose Articles 1, 2 and 3 | Ahead |
| 1 July 2027 | Commission deadline for harmonised limited assurance standards | Ahead, moved from 1 October 2026 |
| 26 July 2028 | Member States must transpose the Article 4 amendments to the due diligence directive | Ahead |
| 1 January 2028 | Financial years from which the Article 40a third-country regime applies | Ahead, unchanged |
The 18 March 2026 date is confirmed inside the text rather than inferred: the new Article 49(2a) of the Accounting Directive confers a delegated power for an indeterminate period from 18 March 2026.
Which dates were deleted, and which merely moved?
The difference matters, because a moved date comes back and a deleted one does not.
| Date in circulation | What actually happened |
|---|---|
| 30 June 2026, first sector-specific ESRS | Deleted. The empowerment itself was removed, not just the deadline |
| 1 October 2026, harmonised limited assurance standards | Moved to 1 July 2027 |
| 1 October 2028, reasonable assurance standards | Deleted. The empowerment was removed |
| Financial year 2026, listed SMEs report | Deleted. That wave is gone |
| Financial year 2028, listed SMEs report after the stop-the-clock | Deleted. There is nothing to postpone |
If a plan on your desk contains any of those five, it was written against a version of the law that stopped being current on 18 March 2026.
What has to be true by 1 January 2027?
One conclusion, documented. Whether your undertaking, or your group on a consolidated basis, exceeds both a net turnover of EUR 450,000,000 and an average of 1,000 employees during the financial year. Both limbs. Exceeding one is not enough, and there is no balance sheet limb in the test.
If the answer is yes, the work that has to be underway before that financial year opens is data collection, not drafting. An emissions inventory that can survive a limited assurance opinion needs a full year of primary records behind it, with scope 2 held on both a location-based and a market-based basis from the first month, because you cannot reconstruct market-based data from meter totals afterwards.
If the answer is no, the date still matters, because it is the point at which your customers' questionnaires change character. From that financial year they are asking you as a supplier rather than as a fellow reporter, and the value chain cap becomes the frame for the conversation. We cover how that works in what a customer may not ask you.
What about the financial years in between?
Financial years 2025 and 2026 are the awkward middle, and they are the reason the calendar above cannot be the whole answer for a company that has already reported.
The first wave was not given a stop-the-clock and was not removed retrospectively. Its window was closed forward, so it runs for financial years starting between 1 January 2024 and 31 December 2026. Separately, Omnibus I gave Member States an option to exempt undertakings that do not exceed the new figures for financial years starting between 1 January 2025 and 31 December 2026. That is a discretion handed to your country, not a relief you can take yourself. Two identically sized companies in two Member States can have different answers for the same financial year.
Why will we not give you a national date?
Because a directive has no national date until a national legislature supplies one, and inventing one would be the single most damaging thing this page could do.
Directive (EU) 2026/470 obliges Member States to have transposing measures by 19 March 2027. What that measure says, when it commences and how it handles the optional 2025 and 2026 relief are questions answered only by your own country's act. Any vendor page, including this one, that states a Dutch, Belgian, German or Irish date without pointing at that country's law is guessing. Ask your auditor or your national ministry, and get the reference.
Which dates are not law yet?
The two delegated acts adopted on 3 July 2026, and this is the most common current error in commentary.
C(2026) 5010 revises the ESRS. C(2026) 5011 establishes the voluntary standards that the value chain cap is measured against, and is written to apply from financial years beginning on or after 1 January 2027. On 28 August 2026 both were still inside the Parliament and Council scrutiny period, so neither had an entry-into-force date. C(2026) 5010 carried an unfilled placeholder in its own text where that date belongs. Until they are published in the Official Journal, the standards in force remain Delegated Regulation (EU) 2023/2772 as amended by (EU) 2025/1416.
What should be in your plan?
Three entries, in this order.
A dated scope conclusion, recorded before your 2027 financial year opens. A data collection start date that sits at least one full reporting year ahead of your first mandatory statement. And a diary note to recheck the two delegated acts, because their publication is the thing most likely to change what you actually have to disclose.
You can put a first inventory together on a free account on the platform, which serves 5,000+ users and covers over 20,000 spend-based and activity-based factors, and see how much of that year of data you already hold. The wider ESRS report is a separate job, which is what CSRD consulting is for.
One honest limit if you are planning against future dates. A small-business reviewer gave Hedgehog 5 out of 5 on G2 in August 2026 and noted that there is no forecasting, and that we had told them it sits on the development list. The platform tells you where you are, not where you will be in 2030.
Sources: Directive (EU) 2026/470 of 24 February 2026, Directive (EU) 2022/2464 Article 5, Directive 2013/34/EU Articles 19a, 29a, 40a and 49, Directive 2006/43/EC Article 26a, Delegated Regulation (EU) 2023/2772, Delegated Regulation (EU) 2025/1416, and Commission acts C(2026) 5010 and C(2026) 5011. Verified 28 August 2026. National transposition determines the date the narrowed scope takes effect in your country.
Facts on this page were last verified on 2026-09-17.
