EU Omnibus I Directive published in the Official Journal of the EU

The Directive (EU) 2026/470 on the changes to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D or CSDDD) under the Omnibus I package (usually referred to as the “Requirements proposal” or “Omnibus I Directive”) has been published today, 26 February 2026, in the Official Journal of the EU. 

The Omnibus I Directive will enter into force on 18 March 2026. EU Member States are required to implement the provisions of the Directive into national law by 19 March 2027 except for the provisions related to the CSDDD which shall be transposed by 26 July 2028.

The Omnibus I Directive made several substantive changes to the CSRD and CSDDD, including (among others): 

CSRD

• Significantly narrowed scope. EU undertakings are now only in scope if they exceed both EUR 450 million net turnover and 1,000 employees on average during the financial year (at individual or group level). Other thresholds were also revised.

• Value chain cap for smaller entities. Undertakings in the value chain that do not exceed an average number of 1,000 employees have the right to decline to provide information exceeding the information specified in the voluntary standards in response to a request made for the purpose of sustainability reporting.

• Information exemptions and reliefs: Undertakings may benefit from limited-time reliefs and specific exemptions allowing them to omit or estimate certain sustainability information, particularly where it cannot be obtained from the value chain or where disclosure would harm protected commercial, legal or security interests.

• Revised ESRS: The Commission must adopt a delegated act to revise the existing European Sustainability Reporting Standards (ESRS) by 18 September 2026.

CSDDD

• Significantly narrowed scope. For EU undertakings, the turnover threshold has been raised to EUR 1,500,000,000 and the employee threshold has been raised to 5,000 employees. Other thresholds have also been amended. 

• Deletion of the transition plan requirement. The provision requiring undertakings to adopt and put into effect a climate transition plan has been deleted in its entirety. However, the requirement under the CSRD to disclose a transition plan (if the undertaking has one) remains.

• Reform of civil liability and reduced penalties. Penalties for non-compliance are to be capped at 3% of the net worldwide turnover of the undertaking. The requirement for a harmonised EU-wide civil liability regime has been deleted. However, civil liability may still arise under the general tort law regimes of many Member States in case damage was directly caused by the breach of the due diligence obligation. 

• Delay of application. The deadline for transposition of the CS3D has been postponed by one year to 26 July 2028, with in-scope undertakings required to comply with the new measures by 26 July 2029 (and to publish disclosures required under CS3D by 1 January 2030). 

Further reading

• EU Omnibus I: CSRD and CS3D amendments finalised: what do you need to know?

• EU: changes to CSRD and CSDD under Omnibus I reach the finish line: video

• CSDDD Quick Guide

• CSRD Quick Guide

• EU CSRD and Omnibus I: Transposition Tracker

• EU CSRD demystified materials

• EU CSDDD explained

• EU Omnibus Tracker