What Did the Omnibus Change for CSRD? A 2026 Guide for Mid-Sized Companies

The EU's Omnibus I directive, in force since March 2026, narrows CSRD to companies with more than 1,000 employees and at least €450 million net turnover. Many mid-sized companies that prepared for CSRD now fall outside mandatory scope, but the pressure from customers, banks and investors has not gone away.

What is the EU Omnibus directive?

The Omnibus I directive, formally Directive (EU) 2026/470, is an EU law that simplifies sustainability reporting and due diligence rules. It amends the CSRD and the Corporate Sustainability Due Diligence Directive by raising thresholds and delaying deadlines. The Council adopted it on 24 February 2026.

The label matters less than the intent. This was a simplification, not a repeal. The reporting obligations still exist, they now apply to far fewer companies, and later. If you read only the headlines, you might think sustainability reporting went away. It did not. It moved.

What did the Omnibus change about CSRD scope?

The Omnibus raised the CSRD threshold to companies with more than 1,000 employees and at least €450 million net turnover. Companies below that line are no longer required to report under the CSRD. The change applies for financial years beginning on or after 1 January 2027.

The threshold sits in Article 19a(1) of Directive 2013/34/EU as amended. The original scope reached down to large public-interest entities with more than 500 employees. Lifting the floor to 1,000 employees and €450 million pulls a large share of previously in-scope mid-sized companies out of the mandate. If you are a 250 to 500-person company, you almost certainly fall outside the new CSRD scope.

What is the "stop-the-clock" measure?

"Stop-the-clock" is the fast-tracked part of the Omnibus that delays CSRD start dates by two years. Companies that were expected to file their first report in 2026, covering financial year 2025, are now expected to report in 2028, covering financial year 2027.

This is why the timeline feels confusing right now. Deadlines that drove a lot of 2024 and 2025 budget decisions have moved, and some of those decisions, like buying a heavy enterprise platform, were made for a date that no longer applies.

I prepared for CSRD but now fall outside scope. What happens?

You land in what we call the reporting vacuum. The legal requirement is gone, but the work you did and the demands on you remain. You are no longer mandated to report, yet your customers and lenders still expect the data.

I spent years building and selling the enterprise ESG platforms that mid-sized companies bought to get CSRD-ready. Many of those companies are now sitting on a system built for an obligation they no longer have. That is the trap: an oversized tool, a vanished mandate, and stakeholders who still ask. The way out is not to stop reporting, it is to right-size it. Start by checking whether the Voluntary Standard is the right move for you.

Do I still have to provide ESG data to customers and banks?

Often, yes. The Omnibus added a value-chain cap: companies with 1,000 or fewer employees can refuse data requests that go beyond the voluntary standard. But large customers, banks and investors still ask, and saying no is rarely a real commercial option.

This is the practical point most coverage misses. The cap protects you from unlimited requests, but it does not remove the demand. What it does is give you a defensible answer: report against the Voluntary Standard, and that is enough to satisfy the people who buy from you and lend to you. You can transition your CSRD preparation into a VSME report without starting over.

What is the Voluntary Standard (VS), and is it the same as VSME?

The Voluntary Standard (VS) is the EU's reporting standard for companies outside mandatory CSRD scope. The European Commission adopted it on 3 July 2026. It builds directly on EFRAG's VSME work and replaces the VSME name, keeping the same two-module structure.

In practice, VS is what most people still call VSME. The content and structure are largely unchanged: a Basic Module and a Comprehensive Module. What changed is the scope and the name. VS is now the designated reference framework for non-listed companies up to 1,000 employees and €450 million turnover, which is exactly the group the Omnibus pushed out of CSRD. One useful detail: unlike ESRS, it does not require a double materiality assessment.

What should mid-sized companies do now?

Don't scrap your CSRD work, recycle it. The fastest path is to convert what you already built into a right-sized VS report that satisfies stakeholders without the enterprise overhead. The data collection and stakeholder dialogues carry over.

My direct advice: stop paying enterprise prices for an obligation you no longer have, and move to a standard built for your size. Most of your competitors do not yet understand the post-Omnibus picture, so moving now is an advantage, not a cost.

See whether the Voluntary Standard is right for you →

Frequently asked questions

When did the Omnibus enter into force?
The Omnibus I directive was adopted on 24 February 2026 and entered into force on 18 March 2026.

What is the new CSRD threshold?
CSRD now applies to companies with more than 1,000 employees and at least €450 million net turnover, for financial years beginning on or after 1 January 2027.

If I'm no longer in CSRD scope, do I still need to report anything?
Often yes, through the Voluntary Standard (VS, formerly VSME), because customers, banks and investors still require ESG data even when the legal mandate no longer applies.

Is VSME still called VSME?
The European Commission adopted it as the "Voluntary Standard" (VS) on 3 July 2026. VSME was the EFRAG working name. The structure and content are largely unchanged.