The EU Omnibus I directive has come into force across EU Member States, reducing reporting obligations under the Corporate Sustainability Reporting Directive (CSRD). In this article, NUS address the latest reporting updates for companies.
Significant Reduction in Company Size and Turnover Thresholds
The Omnibus I directive introduces amendments to both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) with the aim to reduce both the extent of reporting obligations and number of companies required to comply.
The final Omnibus agreement as adopted was significantly more aggressive in cutting reporting requirements when compared with the original proposal, owing to a shifting political and economic climate.
The most significant change to the eligibility requirements was an increase of the company size threshold from 250 to 1,000 employees at minimum and a new requirement for a net turnover of more than €450 million to qualify for mandatory reporting.
For non-EU parent entities, they qualify if they meet this threshold within the EU and have a subsidiary or branch with more than €200m net turnover.
SME Reporting Requirements
A key outcome of these changes is the wholesale elimination of the requirement of SMEs with under 1,000 employees to report.
These businesses have also been further classified as protected undertakings, limiting their obligations to provide value chain data to partners exceeding that covered by the voluntary reporting standard (which expected to be published in 2026).
Overall, the Omnibus directive is expected to reduce the number of companies required to report under the CSRD by 90%.
Latest Draft ESRS
From a sustainability reporting perspective, the ESRS (European Sustainability Reporting Standard), which governs the specific reporting requirements under the CSRD is also undergoing simplification.
The draft of the revised ESRS was submitted to the EU Commission in December late last year and is due to be finalised in the summer this year.
The current revision sets out considerable simplifications including:
- A 61% reduction in required data points
- Greater reliance on materiality assessments
- Increased flexibility in double materiality reporting
Key Considerations
For those companies not already undertaking CSRD reporting as part of wave 1, reporting obligations for companies continuing to qualify under the revised requirements will now commence on 1st January 2027, with the first FY2027 reports expected to be published in 2028 using the revised ESRS. Whilst the Omnibus directive reduces the level of ambition of the CSRD as originally conceived, it does include a review clause, stating that a possible increase in the of scope the directive would need to be considered in the future.
Next Steps
If you require any insight into how the latest changes impacts CSRD reporting for your company, get in touch with your local NUS consultant or email: contact@nusconsulting.com.