CSRD After the Omnibus: What Companies Need to Know and How to Prepare
The Omnibus amendments to the Corporate Sustainability Reporting Directive (CSRD) brought long-awaited clarity. While the scope has been reduced and reporting requirements simplified, the directive’s purpose remains the same: ensuring that sustainability information reflects how companies actually operate and impact people and the environment.
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What is the CSRD?
The Corporate Sustainability Reporting Directive sets the framework for how companies report on sustainability.
CSRD requires companies to disclose:
- How sustainability matters affect their business
- How their business impacts people and the environment
This principle — known as double materiality — remains at the heart of the directive.
CSRD aims to make sustainability reporting more consistent, comparable, and decision-useful for regulators, investors, and other stakeholders.
Who remains in scope
After the Omnibus changes, fewer companies are required to report — but expectations for those in scope are clearer.
CSRD applies to:
- EU companies with more than 1,000 employees and €450 million in turnover
- Non-EU companies with €450 million in EU turnover, including certain subsidiaries and branches
- Listed SMEs are removed from scope
- Certain financial holding companies may be exempt under specific conditions
A review clause allows for possible future changes to scope.
What changed under the Omnibus
The Omnibus amendments focused on simplifying reporting and reducing unnecessary burden.
Key changes include:
- More quantitative and streamlined reporting
- Sector-specific reporting made voluntary
- Smaller business partners no longer required to provide information beyond voluntary standards
- Omission exemptions for trade secrets, classified information, and privacy or security concerns
- Removal of the reasonable assurance requirement (limited assurance remains)
- Introduction of an EU digital portal with reporting templates and guidance
These changes reduce complexity without removing accountability.
What still applies
Despite simplification, core CSRD obligations remain firmly in place.
Companies in scope must still:
- Report across environmental, social, and governance (ESG) topics
- Apply the double materiality principle
- Align disclosures with the European Sustainability Reporting Standards (ESRS)
- Ensure reported information is accurate, consistent, and auditable
CSRD is not about producing more data — it is about producing reliable and meaningful sustainability information.
Timeline toward compliance
The Omnibus changes clarified the reporting timeline.
- National transposition required within 12 months
- Companies already in scope remain subject to CSRD until end of 2026 (with possible national exemptions)
- The new scope applies for financial years starting January 1, 2027
Preparation should begin well before reporting is due, especially where data collection involves multiple teams and suppliers.
Why this matters
CSRD is often described as a reporting directive — but in practice, it tests how well a company understands its own operations and impacts.
Sustainability information that is disconnected from reality will not hold up under scrutiny. This places greater importance on:
- Internal understanding of ESG topics
- Clear roles and responsibilities
- Training that helps people contribute accurate, consistent information



