CSRD and Omnibus I: What Changed on 18 March 2026

This guide breaks down exactly what changed, who is now in scope, who has been removed, and what practical steps you should take before your next compliance review. We have cross-referenced the final directive text published in the Official Journal of the EU on 26 February 2026 to ensure accuracy.

1. What Changed: Old Scope vs. New Scope

The original CSRD, adopted as Directive (EU) 2022/2464, was designed to bring sustainability reporting obligations to a much broader range of companies than its predecessor, the Non-Financial Reporting Directive (NFRD). It introduced a phased rollout with progressively widening scope. Omnibus I has now significantly narrowed that ambition.

The practical effect is dramatic. The European Commission estimated that the original CSRD would cover approximately 50,000 companies across the EU. Under Omnibus I, that number drops to roughly 10,000, an 80% reduction. Companies in the 250-to-999 employee range are the most affected cohort: they were preparing for mandatory reporting, and now find themselves outside the scope entirely (unless listed with over 500 employees).

2. What It Means for the 250-1,000 Employee Market

If your organisation has between 250 and 1,000 employees, the headline is clear: you are no longer subject to mandatory CSRD reporting under EU law. However, that does not mean sustainability data is irrelevant to your operations. Three important factors remain in play.

Value chain data requests. If your company is a supplier to an in-scope company (one with >1,000 employees and >€450M turnover), that company may still request sustainability data from you as part of its own CSRD reporting obligations. However, and this is a crucial protection introduced by Omnibus I, they can only request data up to the level of the Voluntary SME Reporting Standard (VSME). They cannot require you to report against the full European Sustainability Reporting Standards (ESRS). This is a binding limitation, not a recommendation.

Wave 1 transitional reporting. Companies already reporting under Wave 1 (large public-interest entities) will continue their reporting obligations for financial years starting on or after 1 January 2024 through to 31 December 2026. From financial years starting on or after 1 January 2027, these companies will need to reassess their scope under the new Omnibus I thresholds. If they no longer meet the 1,000-employee AND €450M-turnover test, they exit mandatory scope.

Member state discretion. Omnibus I sets the EU-level floor, but individual member states retain the ability to impose broader sustainability reporting requirements through national legislation during the transposition period. The deadline for member state transposition is March 2027. This means that, depending on the jurisdictions you operate in, local requirements may exceed the Omnibus I baseline. Monitor transposition closely in your key markets.

3. The SME Protection Clause

One of the most significant additions in Omnibus I is the explicit SME protection mechanism. Under Article 19a(8) as amended, companies with 1,000 or fewer employees cannot be required, by any in-scope reporting entity in their value chain, to provide sustainability information beyond the scope of the VSME voluntary standard.

This is a direct response to concerns raised during the CSRD consultation period, where SMEs reported anxiety about being overwhelmed by data requests from larger companies. The protection clause creates a hard ceiling: no matter how large your customer is, and no matter how complex their ESRS obligations are, they cannot compel you to report beyond the VSME framework if you have 1,000 or fewer employees.

The VSME standard itself covers basic environmental metrics (scope 1 and 2 greenhouse gas emissions, energy consumption), workforce composition data, and governance basics. It is considerably lighter than the full 12-standard ESRS set. For most SMEs, the VSME disclosure can be prepared with data already available in existing management accounts and HR systems.

4. What to Do Now

The practical next steps depend on where your organisation falls under the new thresholds:

• If you have >1,000 employees AND >€450M net turnover: you are in mandatory scope. If you have not already begun ESRS preparation, start now. The reporting standards are detailed and require substantial data collection across environmental, social, and governance topics. Engage your finance, operations, and sustainability teams immediately.
• If you have between 250 and 999 employees: you are out of mandatory scope at EU level, but you should monitor member state transposition carefully. The deadline for national implementation is March 2027. Some jurisdictions may retain broader requirements.
• If you are a supplier to in-scope companies: prepare VSME-level reporting capability. Even though you cannot be required to go beyond VSME, having this data ready will strengthen your commercial position and reduce friction in procurement processes.
• All companies: use CrowAgent's free CSRD Applicability Checker to confirm your current status under the updated Omnibus I thresholds. The tool reflects the new criteria and will give you a clear answer in under two minutes.

The Omnibus I changes represent the most significant revision to EU sustainability reporting rules since CSRD was adopted in 2022. Whether you are now in scope, newly out of scope, or operating somewhere in the value chain of an in-scope company, understanding the precise boundaries of the new framework is essential. Misinterpreting these thresholds, in either direction, carries real commercial and regulatory risk.

CrowAgent will continue to track the member state transposition process and the forthcoming revised ESRS standards (due 18 September 2026) and update this guide accordingly.