Omnibus I Directive published in EU Official Journal confirming CSRD and CS3D changes

The Omnibus I Directive, amending key EU sustainability legislation, has now been published in the EU Official Journal, confirming previously agreed revisions to the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive (CSDDD, CS3D).

Published on 26 February 2026, the directive formalises changes that have progressed through EU institutions over the past year, following approval by the European Parliament in December 2025 and sign-off by the Council of the European Union on 24 February 2026.

The directive will enter into force on 18 March 2026, with member states required to transpose most provisions into national law by March 2027. The measures form part of the broader Omnibus I package aimed at simplifying sustainability requirements, reducing administrative burden and narrowing the scope of reporting and due diligence obligations.

Changes to the Corporate Sustainability Reporting Directive (CSRD)

The directive significantly narrows the scope of CSRD reporting. EU undertakings will now fall within scope only if they exceed both €450 million in net turnover and an average of 1,000 employees during the financial year, whether assessed individually or at group level. Other thresholds across the framework have also been revised.

Several additional adjustments have been confirmed:

• Value chain reporting limits: companies with fewer than 1,000 employees in the value chain may decline requests for information beyond what is set out in voluntary sustainability reporting standards for SMEs.
• Information reliefs and exemptions: undertakings may omit or estimate certain sustainability disclosures where data cannot reasonably be obtained from the value chain or where disclosure could harm commercial, legal or security interests.
• Revision of reporting standards: the European Commission is required to adopt a delegated act revising the European Sustainability Reporting Standards by 18 September 2026.

These measures are expected to reduce indirect reporting pressure on smaller businesses while maintaining requirements for larger organisations.

Changes to the Corporate Sustainability Due Diligence Directive

The directive also confirms a substantially narrower scope for due diligence obligations. EU undertakings will now be covered only where they exceed 5,000 employees and €1.5 billion in net turnover, with other thresholds amended accordingly.

Key confirmed changes include:

• Removal of the transition plan requirement: the obligation to adopt and implement a climate transition plan under CS3D has been deleted, although companies may still need to disclose a transition plan under CSRD where one exists
• Civil liability reform and penalty cap: the EU-wide harmonised liability regime has been removed, while penalties for non-compliance are capped at 3% of global net turnover; liability may still arise under national legal frameworks
• Extended implementation timeline: member states must transpose the CS3D by 26 July 2028, with in-scope companies required to comply from July 2029 and publish related disclosures from January 2030

The directive also reinforces flexibility in due diligence assessments, allowing companies to prioritise areas of highest risk and rely on reasonably available information.

Implementation and what comes next

With publication now complete, the directive will take effect 20 days after appearing in the Official Journal. Member states will then begin transposing the provisions into national legislation in line with the staggered deadlines.

The directive also amends the EU accounting and audit frameworks alongside sustainability legislation, reflecting its broader role in simplifying corporate reporting obligations.

Background to the Omnibus I package

The Omnibus I revisions were introduced by the European Commission in early 2025 following calls from EU leaders to streamline sustainability regulation and reduce administrative burden, particularly for smaller companies.

The publication in the Official Journal represents one of the final steps in the legislative process, confirming changes that have been subject to extensive negotiation, consultation and public scrutiny across EU institutions.

If you’re in scope of EU sustainability regulations and would like advice, get in touch with Sustainable Energy First.