CSRD After the Omnibus Became Law: The New Waves, Thresholds and Timeline

The CSRD Omnibus is no longer a proposal. Directive (EU) 2026/470, the Omnibus I simplification directive, was published in the Official Journal of the European Union on 26 February 2026 and entered into force on 18 March 2026. It rewrites who reports under the Corporate Sustainability Reporting Directive (CSRD), the EU’s mandatory sustainability reporting law, and when they report. Combined with the earlier stop-the-clock directive, it resets the entire CSRD timeline of waves and thresholds for 2026 and beyond.

Spectreco, an ESG technology and advisory firm with offices in Atlanta, London, Lisbon, and Lahore, works with companies across the EU, GCC, UK, Pakistan, and Australia that are trying to answer one question: given everything that changed, are we still in scope, and if so, for which financial year? This article sets out the post-Omnibus timeline in plain terms, so finance and sustainability leaders can plan against dates that are now law rather than dates that were once expected.

Sources: Latham & Watkins, Gibson Dunn

Is the CSRD Omnibus Now Law?

Yes. The Omnibus I directive was adopted by the Council on 24 February 2026, published in the Official Journal on 26 February 2026, and entered into force on 18 March 2026. The European Parliament had already approved it on 16 December 2025. EU Member States must transpose it into national law by 19 March 2027.

That sequence matters, because “in force” and “applies to your reporting” are two different dates. The directive is binding EU law now. The reporting obligations it reshapes land on specific financial years that run to 2027 and beyond, which the sections below break down.

Sources: Latham & Watkins, Freshfields CSRD tracker

Two Changes, Not One: Stop-the-Clock and the Scope Reset

Much of the confusion around the CSRD timeline comes from treating the Omnibus as a single event. It was two.

The stop-the-clock delay (2025)

The first instrument was the stop-the-clock directive, which the Council gave final approval on 14 April 2025. It did one thing: it postponed reporting by two years for companies that had not yet started reporting under CSRD, and for listed small and medium-sized enterprises. It changed the dates, not the scope.

Source: Council of the EU

The Omnibus I content directive (2026)

The second instrument, Directive (EU) 2026/470, is the one that reset the scope. It raised the thresholds sharply, removed listed SMEs from mandatory scope, and set a deadline for simplified reporting standards. This is the directive that took most mid-market companies out of the mandatory CSRD perimeter.

Read together, stop-the-clock moved the clock and Omnibus I changed who the clock applies to. You need both to read the current timeline correctly.

Source: Gibson Dunn

Who Reports Under CSRD After the Omnibus?

CSRD now applies to EU undertakings that exceed both of two thresholds at the same time. Meeting only one is not enough.

• More than 1,000 employees on average during the financial year
• More than EUR 450 million in net annual turnover

The old test, which caught companies meeting two of three criteria at 250 employees, EUR 40 million turnover, or EUR 20 million balance sheet, is gone. Non-EU parent groups remain in scope where they generate more than EUR 450 million in net turnover inside the EU through a qualifying subsidiary or branch. Listed SMEs are removed from mandatory scope entirely.

The practical effect is large. ISS-Corporate estimates that roughly 85 to 90 percent fewer companies now sit inside mandatory CSRD scope than the original framework expected. Spectreco’s own guidance puts the remaining mandatory population at around 1,000-plus-employee companies, a fraction of the tens of thousands the original directive was expected to capture.

Sources: Latham & Watkins, ISS-Corporate

The New CSRD Reporting Waves and Timeline

After stop-the-clock and Omnibus I, the reporting waves look like this. Wave 1 is unchanged. Wave 2 moved by two years. Wave 3 effectively disappeared from the mandatory regime.

Two points matter for planning. Wave 1 companies that no longer meet the 1,000-employee and EUR 450 million test can fall out of mandatory scope for financial years 2025 and 2026 onward. Wave 2 companies that once braced for a 2026 report covering FY2025 now file their first CSRD report in 2028 covering FY2027. As of early September 2026, five Member States had still not transposed the rules, so national timing can vary.

Sources: Coolset, Freshfields CSRD tracker

What “out of scope” actually means

Here is the part the timeline alone does not tell you. The Omnibus reduced the legal obligation to report. It did not reduce the amount of ESG data companies are asked to produce. Those two things came apart.

In-scope Wave 1 banks and large corporates still have to complete their own disclosures, and that means collecting Scope 3 emissions and supplier data from companies far below the 1,000-employee line. The voluntary VSME standard exists precisely to standardize those value-chain requests. So a company that is legally out of scope is often still commercially in scope, through its customers, its lenders, and any public sustainability claim it makes. Spectreco’s analysis of why being out of CSRD scope does not mean being out of the market works through what that means for suppliers and mid-market firms.

Source: European Commission

What Happened to the ESRS? The Simplified Standards Are Adopted

The Omnibus did not only change who reports. It changed what they disclose. The European Sustainability Reporting Standards (ESRS) are the detailed rules that set out the specific datapoints a CSRD report must contain.

On 3 July 2026, the European Commission adopted the delegated act revising the first set of ESRS. The revision cuts the number of mandatory datapoints by over 60 percent and total datapoints by more than 70 percent. A voluntary sustainability reporting standard for smaller companies, known as the VSME, was adopted alongside it as the reference point for value-chain data requests.

The revised standards go through a scrutiny period of two months by the European Parliament and Council, which can be extended by a further two months, and are expected to apply for FY2027 reporting. For a fuller breakdown of the disclosure rules, see Spectreco’s guide to the revised ESRS and CSRD disclosure requirements, and for suppliers below the threshold, the VSME standard for SME suppliers.

Source: European Commission

How to Confirm Your CSRD Reporting Wave and Timeline

Use these steps to place your company on the post-Omnibus timeline.

1. Test both thresholds together. Confirm whether the entity exceeds both 1,000 employees on average and EUR 450 million in net turnover in the same financial year. If it clears only one, it is outside mandatory scope.
2. Identify your wave. A Wave 1 reporter reassesses whether it still qualifies. A previously expected Wave 2 reporter now targets FY2027, with the first report in 2028.
3. Check your Member State transposition. National timing can differ until all Member States transpose the directive by 19 March 2027, so confirm the rules in each country where you report.
4. Map to the revised ESRS. Rebuild your datapoint list against the simplified ESRS adopted on 3 July 2026 rather than the original set, so you collect only what is required.
5. Plan for value-chain requests. If you fall out of mandatory scope, prepare a baseline aligned to the VSME standard, because customers, banks, and investors will still ask.

Frequently Asked Questions

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Get Your CSRD Timeline Confirmed

The post-Omnibus rules reward companies that know exactly where they stand: in scope for FY2027, newly out of scope, or facing value-chain requests regardless. Guessing at the wave or the threshold is how teams either over-invest in reporting they no longer owe or miss an obligation that is still live.

Book a CSRD readiness review with Spectreco’s Compliance, Reporting and Disclosures advisory team to confirm your wave, threshold status, and FY2027 timeline, and power the reporting with the Spectreco Platform.

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