The EU Omnibus Directive (2026/470): What Changes for CSRD and CSDDD

Directive (EU) 2026/470 of 24 February 2026, known as Omnibus I, limits the CSRD to undertakings with more than 1,000 employees and EUR 450 million in net turnover, and the CSDDD to groups with more than 5,000 employees and EUR 1.5 billion in turnover, from 26 July 2029. It entered into force on 18 March 2026, with transposition due by 19 March 2027 (CSRD) and 26 July 2028 (CSDDD). Double materiality survives; the board's oversight calendar does not.

From Stop-the-Clock to Omnibus I: the timeline

Omnibus I is the second step of a simplification the European Commission launched in February 2025. It amends two directives that were already law and, in most Member States, a CSRD that was already transposed.

1. 14 December 2022: CSRD adopted. Directive (EU) 2022/2464 introduces mandatory sustainability reporting under the European Sustainability Reporting Standards (ESRS).
2. 13 June 2024: CSDDD adopted. Directive (EU) 2024/1760 creates an EU-wide duty to identify and address adverse human rights and environmental impacts.
3. 14 April 2025: Stop-the-Clock. Directive (EU) 2025/794 postpones CSRD reporting for the second and third waves by two years and delays the CSDDD by one year.
4. 24 February 2026: Omnibus I adopted. Directive (EU) 2026/470 is published in the Official Journal on 26 February and enters into force on 18 March 2026.

CSRD after Omnibus: who still reports, and when

The headline change is scope. The new criteria are cumulative and apply at individual or group level, which removes the large majority of companies the original directive was expected to cover.

• Higher thresholds. More than 1,000 employees on average during the financial year and more than EUR 450 million in net turnover.
• Non-EU groups. More than EUR 450 million in EU turnover in each of the last two consecutive years, with an EU subsidiary or branch generating more than EUR 200 million.
• Listed SMEs removed. They are no longer subject to mandatory reporting.
• Value-chain cap. Companies with up to 1,000 employees can decline information requests that go beyond the voluntary SME reporting standard.
• No sector standards. The Commission loses its mandate to adopt mandatory sector-specific ESRS and may issue sector guidance instead.

Revised ESRS and assurance

Omnibus I also lightens what a report contains, without changing its foundations. Double materiality remains the starting point of every assessment.

• Revised ESRS. The delegated act adopted by the Commission on 3 July 2026, based on proposals from EFRAG, cuts the number of mandatory datapoints and adds new reliefs; it is under scrutiny by the European Parliament and the Council.
• Application date. Mandatory for financial years starting on or after 1 January 2027, with early application to 2026 permitted once the act is in force.
• Limited assurance only. The planned move to reasonable assurance is dropped; harmonised limited assurance standards are due by 1 July 2027.
• Protected information. Undertakings may omit information whose disclosure would seriously harm protected commercial, legal or security interests.

Earlier analysis of the original reporting obligations remains useful background: see our pieces on CSRD reporting requirements and the CSRD timeline, both now updated with an Omnibus note.

CSDDD after Omnibus: narrower, later, lighter

The due diligence directive is the more deeply rewritten of the two. The obligation to conduct due diligence survives, but its reach, intensity and consequences are all reduced.

• Thresholds. More than 5,000 employees and more than EUR 1.5 billion in net worldwide turnover for EU companies; more than EUR 1.5 billion in EU turnover for non-EU companies.
• Dates. Transposition by 26 July 2028, application from 26 July 2029, annual statement for financial years starting on or after 1 January 2030.
• Risk-based approach. A scoping exercise identifies where adverse impacts are most likely, followed by an in-depth assessment of those areas.
• No mandatory termination. Ending a business relationship is no longer required; suspension remains the last resort.
• No transition plan. The obligation to adopt a climate transition plan is deleted from the CSDDD.
• Liability and penalties. The harmonised EU civil liability regime is removed in favour of national law; fines are capped at 3% of net worldwide turnover.

The European Commission must publish its first guidelines on the due diligence process by 26 July 2027. The directive keeps its alignment with the OECD Guidelines for Multinational Enterprises, and existing national regimes such as the French duty of vigilance law continue to apply until transposition.

What boards should do now

Fewer companies are in scope, but those that remain face a moved calendar and several choices that only the board can sign off. Five actions belong on the next audit committee agenda.

1. Re-test scope. Apply the new thresholds to the last two financial years, at individual and group level, and record the result.
2. Reset the audit committee plan. Its remit covers monitoring of sustainability reporting; align the work programme with the actual date of the first report.
3. Decide on early application. Choose between the current and the revised ESRS for financial year 2026.
4. Track national transposition. Exemptions for first-wave reporters and the interplay with existing due diligence laws are set Member State by Member State.
5. Document the decisions. Minute the reasoning behind any deferral or exit from scope, so it can be produced to auditors, regulators or investors.

For the governance practices that support these decisions, see our board governance best practices.

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