03/03/2026
Insights Blog

The Omnibus I Directive, amending the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD), was published in the Official Journal of the EU on 26 February 2026 and will enter into force on 18 March 2026, formally completing the EU legislative process.

Member States, including Ireland, are generally required to transpose the Omnibus I Directive’s provisions by 19 March 2027. The CSDDD-related provisions must be transposed by 26 July 2028.

The Omnibus I amendments significantly narrow the scope of both the CSRD and CSDDD and remove or reduce key obligations under both regimes. As a result, many companies that were previously within scope may no longer be subject to these requirements. These updates represent a significant recalibration of EU sustainability reporting and due diligence requirements, aimed at aligning timelines and reducing administrative burdens, while maintaining the core objectives of transparency, accountability, and double materiality.

CSRD

  • Scope (EU Companies): The revised CSRD applies to EU companies with more than EUR 450 million net turnover and 1,000 employees, assessed on a standalone or consolidated basis.
  • Scope (Non-EU Parent Companies): Non-EU parent companies fall within scope where they generate net turnover exceeding EUR 450 million in the EU, with an EU subsidiary or branch generating net turnover exceeding EUR 200 million.
  • Timeframes: The Omnibus I amendments do not alter the CSRD reporting timeframes as previously amended by the “Stop-the-Clock” Directive, which entered force in April 2025. “Wave 2” companies that remain within the revised scope will first report in 2028 in respect of financial years starting on or after 1 January 2027. The Omnibus I Directive permits Member States a discretion (but not the obligation) to exempt “Wave 1” companies that now fall outside the revised scope thresholds, from reporting obligations that would otherwise arise in 2026 and 2027.
  • Value Chain Cap: Reporting companies are limited in the information they can request from smaller undertakings (fewer than 1,000 employees) in their value chain.
  • ESRS Simplification: The European Commission is due to adopt revised European Sustainability Reporting Standards (ESRS) by delegated act within six months of the entry into force of the Omnibus I Directive (by 18 September 2026). The Commission has previously indicated an intention to adopt the revised ESRS by mid-2026 and it is anticipated that the final draft ESRS will be published for public consultation prior to formal adoption. Sector-specific standards have been removed.
  • Assurance: The requirement for third-party assurance is retained but will remain on a limited assurance basis, rather than progress to a reasonable assurance standard.

CSDDD

  • Scope: The revised CSDDD applies to EU companies with more than EUR 1.5 billion net turnover and 5,000 employees, and to non-EU companies exceeding EUR 1.5 billion in EU net turnover. In each case, the thresholds are assessed on a standalone or consolidated basis.
  • Climate Transition Plan: The obligation to adopt and put into effect a transition plan for climate change mitigation is removed.
  • Civil Liability: The EU harmonised liability regime is removed. Civil liability for breaches of CSDDD obligations will now be determined by the law of individual Member States.
  • Timeframe: The CSDDD transposition deadline is extended to 26 July 2028, with in-scope companies subject to the CSDDD obligations from July 2029.

The Omnibus I amendments represent a material evolution of the EU’s sustainability landscape, creating a coordinated long‑term horizon for both sustainability reporting and due‑diligence obligations. Companies should reassess their CSRD applicability and reporting frameworks and evaluate their readiness for the CSDDD regime. The next six to twelve months, leading into national transposition of Omnibus I and the adoption of simplified ESRS, will be critical for planning and compliance readiness.