The minute
- After Omnibus I (in force since March 2026), only companies with more than 1,000 employees and over €450 million in turnover must report under the CSRD
- The first report under the revised rules covers fiscal year 2027, published in 2028
- Non-EU companies with significant revenue or activity in the bloc can still be caught, even without an EU headquarters
Why it matters: For companies that were preparing since before Omnibus, the narrower scope may mean the obligation isn’t immediate anymore, but suppliers to a company that is in scope stay under indirect pressure to provide the data anyway.
What the CSRD actually requires
The CSRD requires companies to report sustainability data to an auditable standard, covering environmental, social and governance topics, using the European Sustainability Reporting Standards (ESRS) as reference. Reporting follows the double materiality principle: what financially affects the company, and what the company affects in the world.
Who’s in scope after Omnibus I
The Omnibus I package, in force since 18 March 2026, raised the threshold to companies with more than 1,000 employees and over €450 million in turnover. That removed most mid-sized companies that would have been in the original scope, but kept large companies and any non-EU company with significant activity in the bloc.
Updated deadlines
The first report under the revised rules covers fiscal year 2027, expected to be published in 2028. Member states have until 19 March 2027 to transpose the Omnibus I changes into national law.
How to prepare even outside direct scope
Smaller companies supplying a company under the CSRD still get contractual requests for sustainability data, so it’s worth organizing emissions measurement and internal policies before being asked.
Frequently asked questions
Does my non-EU company need to follow the CSRD?
Only if it has revenue or significant activity in the EU that puts it in the scope defined by Omnibus I.
Does the CSRD replace Brazil’s SBCE?
No. The CSRD is about sustainability reporting; the SBCE is Brazil’s regulated carbon market. They’re different rules that can apply to the same company.
What is double materiality?
Reporting both the financial impact sustainability issues have on the company, and the impact the company has on the environment and society.
Read next: what the CSRD is, in a quick definition.
Read next: what double materiality is.