CSRD Omnibus I: What Changed and What It Means for Suppliers

Omnibus I is the EU's 2026 simplification of the CSRD and the CSDDD. It was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026 as Directive (EU) 2026/470. For most manufacturers and suppliers the changes that matter are the narrower scope and the new limit on what large companies can ask of smaller suppliers. The earlier version of this article had several details wrong, including what the 61% figure refers to, so I rebuilt it.

What Changed

The Value Chain Cap

This is the change that matters most for suppliers. A reporting company may not require information from a supplier or other counterparty with 1,000 or fewer employees beyond limits aligned with the voluntary reporting standard. Such a company has a statutory right to refuse requests beyond the cap, and the reporting company must tell it so. A reporting company may rely on a counterparty's self-declaration without further verification unless it has clear reason to doubt it. A company that stays within the cap is treated as having met its value chain reporting obligations, including through the use of estimates.

The earlier version of this article said the cap is set by "Annex II of the VSME" and that firms with 10 or fewer employees face a shorter list. I could not confirm either. The voluntary standard has a Basic Module and a Comprehensive Module; the May draft numbered them B1–B11 and C1–C9. It entered into force on 24 September 2026. I did not check whether the final numbering is unchanged, so check the text. The cap covers requests made for CSRD reporting. It may not limit requests under other laws or customer programmes.

Timing

The delay of waves 2 and 3 was not part of Omnibus I. It came from the earlier "stop-the-clock" directive, which entered into force in April 2025, and Omnibus I does not change those dates. Companies in wave 2 that remain in scope first report in 2028, for financial years starting on or after 1 January 2027. Member States may, but need not, exempt wave 1 companies that now fall outside the thresholds from reporting in 2026 and 2027. Member States generally have until 19 March 2027 to transpose the CSRD changes, so national details will still vary. Listed SMEs were part of the earlier waves; I could not confirm their treatment in the final text, so check it.

Sector Standards, Materiality and Assurance

The Commission's power to adopt mandatory sector-specific standards, which would have covered sectors such as textiles, was removed to avoid adding datapoints. Double materiality stays. The earlier version of this article said Omnibus I tightened materiality thresholds. I found no support for that. The May draft of the revised ESRS instead allowed a top-down approach at topic level and said companies must not report information that is not material; I have not checked the final text on this. Limited assurance remains the standard, and the deadline for the Commission to adopt limited assurance standards moved to 1 July 2027.

The earlier version also referred to a 2028 review clause. I could not find it in the sources I read, so I removed it. The review dates I did find, 26 July 2028 and 26 July 2029, concern the CSDDD, not the CSRD.

What It Means for Suppliers

Practical steps

• Check your headcount. At 1,000 employees or fewer you are in the protected group and can refuse requests beyond the cap.
• If a customer's request goes beyond the voluntary standard, say so in writing and answer only what the cap allows, if you choose to.
• Prepare a single standard dataset based on the voluntary standard's basic module, and use it to answer all customers.
• Keep supporting records. A customer can rely on your self-declaration unless it has clear reason to doubt it, so errors can still come back to you.
• Expect requests under other laws and programmes to continue; the cap covers CSRD requests only.
• Read the voluntary standard (in force 24 September 2026) and the revised ESRS (adopted 3 July 2026, applying from FY2027) before you answer.

Frequently Asked Questions

References

Directive (EU) 2026/470 (Omnibus I), published 26 February 2026. Arthur Cox, Omnibus I Directive published: revised scope and reduced obligations under CSRD and CSDDD. Morrison Foerster, EU Sustainability Omnibus I: the detailed omnibus adopted (December 2025), and European Commission Proposes Revised ESRS (May 2026). The pre-Omnibus scope row is from my own knowledge. These are law-firm summaries, so confirm details in the official text.