Directive (EU) 2026/470, the first Omnibus package, entered into force on 18 March 2026.
For the CSRD, mandatory reporting now applies only to companies with more than 1,000 employees and more than EUR 450 million in net turnover. Listed SMEs are no longer in scope. Non-EU groups are in scope when the ultimate parent has more than EUR 450 million of EU turnover for two years in a row and an EU subsidiary or branch is above EUR 200 million.
For the CSDDD, scope is limited to EU companies with more than 5,000 employees and EUR 1.5 billion turnover, and non-EU companies with more than EUR 1.5 billion of EU turnover. The duty to adopt a climate transition plan is removed, penalties are capped at 3% of worldwide turnover, and the EU-wide civil liability rule is dropped.
Member States must transpose the CSRD changes by 19 March 2027 and the CSDDD changes by 26 July 2028. Smaller companies in a reporting company's value chain can decline excessive data requests.
What to do: check whether your readiness plan still applies under the new thresholds, and expect revised ESRS and a voluntary standard for smaller companies.
Source: CMS