CSRD after Omnibus I: sustainability reporting only for 1,000+ employee companies from FY2027; SMEs out of scope with VSME value-chain cap
Date note: Omnibus I Directive published OJ 2026-02-26, in force 2026-03-18. Companies newly in scope report on FY2027 in 2028; wave-2/3 companies were 'stopped' in 2025
What changes
The Omnibus I package cut CSRD scope to companies with more than 1,000 employees and over €450M turnover; listed SMEs are removed entirely. Large customers may not demand more sustainability data from suppliers below 1,000 employees than the voluntary VSME standard. In-scope companies report for financial year 2027 in 2028.
Who is affected
Large companies above the new thresholds must report; SMEs are affected only as suppliers being asked for VSME-level data.
Sizes: large · Sectors: All sectors
What to do
Large companies: confirm whether you exceed both thresholds and prepare ESRS-based reporting for FY2027. SMEs: use the VSME standard as your maximum response to customer ESG questionnaires and decline requests going beyond it; consider a lightweight VSME report to keep bank and customer relationships smooth.
Sources
- Council of the EU – Council signs off simplification of sustainability reporting and due diligence (24 Feb 2026) (www.consilium.europa.eu)
- Accountancy Europe – Omnibus explained: key changes to CSRD and CSDDD (accountancyeurope.eu)
Last verified 7 September 2026. Informational only, not legal advice.