The CSRD Omnibus 2026 significantly changes ESG reporting rules and is forcing many companies to reassess whether they are still subject to reporting obligations. Following the EU Council’s approval of the simplification package on February 24, 2026, and the publication of Directive 2026/470, businesses are primarily analyzing whether they will still be required to report after the changes, when the new obligations will apply to them, and what actions they should plan for 2026.
The Omnibus I package does not repeal the requirements under the CSRD, but it significantly modifies the scope of entities subject to reporting, the timeline, and selected elements of the ESRS standards. The key change is the narrowing of the group of entities required to report ESG data to those entities and corporate groups employing more than 1,000 employees and generating more than €450 million in annual net revenue.
Table of Contents
- What Is The Omnibus Package I?
- Does CSRD Still Apply After Omnibus?
- Who Is Subject to CSRD After The Omnibus Package I?
- Will My Company Fall Outside the Scope of CSRD After Omnibus?
- ESG Reporting Deferral – What Does It Mean in Practice?
- ESRS Simplifications – What Is Changing?
- CSRD in Poland 2026 – What Should Companies Do?
- ESG Obligations in 2026 – What Should the Board and CFO Check?
- Does Omnibus Package I Mean the End of ESG Preparation?
- Common Mistakes After Omnibus Package I
- CSRD Omnibus 2026 – Summary
- FAQ – Frequently Asked Questions About CSRD Omnibus 2026
What Is The Omnibus Package I?
Omnibus Package I is a set of EU changes to sustainability and ESG rules. The goal is to limit the administrative workload and simplify reporting duties. The package includes:
- Narrowing the scope of entities covered by the CSRD
- Limiting what reporting entities can ask from parties in the value chain
- Clarifying when classified information, trade secrets, and sensitive data may be left out
- Exempting financial holding companies from the CSRD
- Allowing certain issuers to skip individual or consolidated ESG reporting if a parent entity’s report covers them
- Keeping attestation at the level of limited assurance
For changes on sustainability reporting, EU member states must transpose the directive into national law by 19 March 2027. A separate deadline applies to some changes to corporate due diligence.
Does CSRD Still Apply After Omnibus?
Yes. Omnibus Package I does not remove CSRD obligations. The EU is not stepping back from ESG reporting. The changes focus on three things: simplifying the system, narrowing the scope of entities covered, and cutting some admin burdens.
For most companies, the real question is not whether CSRD still applies. It is whether their organisation is still in scope after the changes. Some businesses will still have to report on ESG. Some duties have been delayed. Some requirements will apply, but in a simpler form.
Who Is Subject to CSRD After The Omnibus Package I?
After the Omnibus Package I, ESG reporting duties apply mainly to the largest entities and corporate groups. The key thresholds are more than 1000 employees and net revenue above 450 EUR million per year. Each company’s status should be checked carefully. This is especially true for corporate groups and cross-border structures.
For certain non-EU entities, separate thresholds apply based on EU market activity. The updated rules apply where a non-EU entity earns more than EUR 450 million in net revenue in the EU. Its EU subsidiary or branch must also exceed EUR 200 million.
| Entity Type | Situation After The Omnibus Package I |
| Entities and corporate groups with more than 1000 employees and more than 450 EUR million in net revenue | Generally remain within the scope of ESG reporting. |
| First-wave entities that fall outside the new scope | May use the exemption from reporting for 2025 and 2026. |
| Financial holding companies | Exempt from the scope of the CSRD. |
| Issuers covered by a parent entity’s report | May be exempt from their own ESG reporting. |
| Entities in the value chain | Reduced scope of information that reporting entities may request. |
| Certain non-EU entities | Obligations may arise once EU-activity thresholds are exceeded. |
A company that was preparing for CSRD before the Omnibus Package I cannot assume its duties are unchanged. A fresh review is needed. This should cover company status, financial data, headcount, group structure, and the reporting timeline.
Will My Company Fall Outside the Scope of CSRD After Omnibus?
After the Omnibus Package I, checking whether your company was on the previous CSRD timeline is not enough. A new review is needed based on the updated criteria. The key factors are the employment threshold and net revenue.
First-wave entities need special attention. These are entities preparing a sustainability report for the first time for the 2024 financial year. First-wave entities that fall outside the new scope may be exempt from reporting for the 2025 and 2026 financial years.
This does not mean every company on the old timeline automatically falls out of scope. What matters is the specific data: headcount, financials, group status, any listing on a regulated market, and the relationship with a parent entity.
ESG Reporting Deferral – What Does It Mean in Practice?
One of the biggest effects of the 2026 ESG reporting changes is the delay or reduction of duties for some entities.
In Poland, the first stage of implementation was introduced by the Act of 27 February 2026 amending the Accounting Act. This law lets certain first-wave entities choose not to prepare ESG reports for 2025 and 2026. This applies if they will no longer be in scope under the new rules.
A deferral does not mean preparations can stop. For many businesses, this is extra time to sort out processes, data collection systems, double materiality reviews, and reporting procedures. The expectations of corporate groups, banks, investors, and counterparties also matter. They may still ask for ESG data regardless of any formal reporting duty.
ESRS Simplifications – What Is Changing?
Omnibus Package I also brings simplifications to the ESRS — the European Sustainability Reporting Standards. Separate quick-fix guidance for the first set of ESRS is also available. This allows certain disclosures to be skipped for the 2025 and 2026 financial years.
The key directions of change include:
- Fewer mandatory data’
- Simpler disclosures in some areas
- More proportionate requirements
- Lower burden for certain corporate groups
- Less data duplication
- Limiting the cascade effect on smaller entities in the value chain
The simplifications do not make ESG reporting a formality. Proper records of data, processes, and reporting methods are still needed.
CSRD in Poland 2026 – What Should Companies Do?
The most important step right now is to review obligations in light of Omnibus Package I. Poland has started implementing the changes in stages.
The first stage introduced the option to skip reporting for 2025 and 2026 for first-wave entities outside the new scope. The rest of the directive’s provisions will be implemented in a second stage. Some practical effects will depend on the national laws that follow.
Each company should check:
- Whether it is still subject to a reporting duty
- From when the duty will apply
- Whether it can use an exemption or simplified rules
- Whether its current implementation plan needs updating
- What data still needs to be reported
- Whether ESG duties will also arise from group, bank, investor, or counterparty relationships
Reviewing the situation in corporate groups is especially important. ESG duties often go beyond a single company and affect relationships within the group.
ESG Obligations in 2026 – What Should the Board and CFO Check?
After the Omnibus Package I, each company should conduct a brief reporting status review. Start with the basics: does headcount exceed 1000? Does net revenue exceed 450 EUR million per year? What is the company’s role in its corporate group? Was it part of the first wave?
Then check whether the company can use the exemption for 2025 and 2026. Confirm whether it stays in CSRD scope, reports on its own, or will be covered by a parent entity’s consolidated report.
At the same time, check the market and contract expectations. The duty to provide ESG data can come from business relationships, group policies, financing terms, or procurement rules of larger clients.
Does Omnibus Package I Mean the End of ESG Preparation?
No. Some duties have been delayed or simplified. But many organisations should keep building their ESG processes.
This applies above all to companies that remain in scope, and to those that will supply ESG data to corporate groups, banks, investors, or counterparties.
The following areas remain relevant:
- Data collection systems
- ESG policies
- Compliance procedures
- Risk analysis
- Internal reporting
- Cooperation with corporate groups
- Responding to counterparty inquiries on environmental, social, and governance data
Even if a company has no direct reporting duty, it may still get requests from reporting entities, banks, investors, or counterparties.
Common Mistakes After Omnibus Package I
After the simplification package was adopted, many companies assumed ESG duties had been fully removed. Others believed that all preparation work could stop. Both assumptions are wrong.
| Most Common Mistake | Potential Risk |
| Assuming CSRD no longer applies | Failure to prepare for future obligations |
| Ignoring the 1000-employee and 450 million EUR revenue thresholds | Wrong assessment of reporting status |
| Stopping all ESG implementation work | Operational problems when implementation resumes |
| Not checking the exemption for 2025 and 2026 | Incorrect project timeline |
| Ignoring corporate group requirements | Contractual and operational risks |
| Not collecting ESG data | Difficulties when reporting or responding to inquiries later |
| Treating simplifications as a full exemption | Incorrect compliance assessment |
In most cases, the right move is not to stop ESG work. It is to adjust the timeline and scope of preparation to fit the new rules.
CSRD Omnibus 2026 – Summary
CSRD Omnibus 2026 does not end ESG reporting. It does change the timeline and scope of some duties. Omnibus Package I simplifies the ESRS standards, delays some reporting duties, and cuts certain administrative burdens. The key change is the narrowed scope. Reporting now applies mainly to entities and corporate groups with more than 1000 employees and net revenue above 450 million EUR per year.
For businesses, the top priority is a fresh review of company status. The question is whether the organisation is still in scope after the changes, and from when the duties will apply.
Many companies should keep preparing even if some duties have been pushed back. This is especially true for corporate groups, large businesses, and entities working with investors, banks, or counterparties that need ESG data.
Are you unsure whether your company is still subject to ESG obligations after Omnibus Package I?
Contact us. We can assess your company’s status, review the impact of the simplification package on your reporting duties, and help prepare your organisation for the new ESG reporting rules.
FAQ – Frequently Asked Questions About CSRD Omnibus 2026
1. Did Omnibus Package I abolish ESG reporting?
No. Omnibus Package I does not repeal the CSRD or ESG reporting duties. It brings simplifications, delays some obligations, and changes certain ESRS requirements.
2. Who is still subject to CSRD after the changes?
After the Omnibus Package I, ESG reporting duties apply mainly to entities and corporate groups with more than 1000 employees and net revenue above 450 million EUR per year. In many cases, a fresh review of the company’s status is still needed. This is especially true for corporate groups and international structures.
3. Has ESG reporting been deferred?
Yes, for some businesses. A deferral applies to certain reporting duties. First-wave entities outside the new scope may also be exempt from reporting for 2025 and 2026.
4. What do the ESRS simplifications change?
The changes reduce the amount of required data and simplify some disclosures. Proper records of ESG data and processes are still needed.
5. Should small and medium-sized businesses still prepare for ESG?
In many cases, yes. Even if the formal reporting duty has been delayed or simplified, ESG data may still be required by corporate groups, investors, banks, or counterparties.
6. Does a company outside the CSRD scope still need to collect ESG data?
Not every company that was preparing for CSRD will face a formal sustainability reporting duty. But that does not mean it will never be asked for ESG data. Requests can come from reporting entities, corporate groups, banks, investors, or counterparties.
7. Is the Omnibus Package I already in force?
Yes. The EU Council approved the simplification package on 24 February 2026. Directive (EU) 2026/470 of the European Parliament and of the Council was published on 26 February 2026. Member states must generally transpose the sustainability reporting changes by 19 March 2027.