The Sustainability Omnibus (Omnibus I, Directive (EU) 2026/470): What Changed in the CSRD, the ESRS and the Timeline

Both values must be exceeded together, by the undertaking itself or by its group on a consolidated basis, in financial years starting on or after 1 January 2027.

Omnibus I is an amending directive, so Member States must transpose its Articles 1 to 3 by 19 March 2027 (Article 5(1)), and companies are bound once their national law changes. The follow-up standards are delegated regulations and apply directly. Omnibus I changes who reports, from which financial year and against which standards; the reporting regime itself, from double materiality to the sustainability statement, is covered where the Corporate Sustainability Reporting Directive (CSRD) is explained.

This page follows Directive (EU) 2026/470 from the two proposals to the Official Journal, lists each change with the article that made it, names what stayed the same, and gives the dated status as of 29 October 2026, up to the review reports due in 2029 and 2031.

What Is the Sustainability Omnibus?

The sustainability Omnibus, also called Omnibus I, is the package of proposals the Commission presented on 26 February 2025 to simplify EU sustainability reporting, and for the CSRD it produced two directives: the Stop-the-clock Directive (EU) 2025/794 and the content Directive (EU) 2026/470. The content directive amends three acts on the reporting side. Article 1 amends the Audit Directive 2006/43/EC, Article 2 amends the Accounting Directive 2013/34/EU and Article 3 amends the CSRD, Directive (EU) 2022/2464, mainly its application dates in Article 5 and its review clause in Article 6. Every change on this page is cited as an article of Directive 2013/34/EU, because the CSRD inserted its reporting rules into the Accounting Directive as Articles 19a, 29a to 29d and 40a to 40d. Omnibus I itself inserted three further articles, 29ca, 29e and 29f, and deleted Article 29c.

The closing articles carry the procedure. Article 5 sets the transposition deadline of 19 March 2027 for Articles 1 to 3, Article 6 sets entry into force on the twentieth day after publication in the Official Journal, and Article 7 addresses the directive to the Member States. The same act also amended the due-diligence rules separately (Article 4); this page covers the reporting side only.

The Two Proposals of 26 February 2025 and the Two Directives They Became

COM(2025) 80 proposed postponing the CSRD reporting dates and became the Stop-the-clock Directive (EU) 2025/794 of 14 April 2025, and COM(2025) 81 proposed the content changes and became Directive (EU) 2026/470 of 24 February 2026. The two proposals ran as separate legislative procedures, 2025/0044(COD) for the postponement and 2025/0045(COD) for the content. Recital 3 of Directive (EU) 2025/794 gives the reason for the first step: while the simplification initiatives were ongoing, and to avoid the undertakings due to report for financial years beginning on or after 1 January 2025 and 1 January 2026 "incurring unnecessary and avoidable costs", their reporting requirements were postponed by two years.

The stop-the-clock step entered into force on 17 April 2025 and had to be transposed by 31 December 2025 (Article 3(1) of Directive (EU) 2025/794). It moved the former second wave from financial year 2025 to financial year 2027 and the former third wave from 2026 to 2028, a third wave that Directive (EU) 2026/470 later deleted.

How Directive (EU) 2026/470 Became Law

Directive (EU) 2026/470 went through procedure 2025/0045(COD) in about 12 months: the Commission proposal of 26 February 2025, a political agreement in December 2025, Parliament's first-reading vote on 16 December 2025, Council adoption and signature on 24 February 2026, publication in the Official Journal on 26 February 2026 and entry into force on 18 March 2026. The proposal COM(2025) 81 was presented together with COM(2025) 80 and was adopted in amended form, with scope values different from those the Commission had proposed.

The Legal Affairs Committee (JURI) of the European Parliament was the committee responsible. On 22 October 2025 the plenary rejected the committee's mandate to open negotiations (Rule 72 of Parliament's Rules of Procedure). The Commission's press release IP/25/2981 dates the political agreement between Parliament and Council to 9 December 2025. Parliament then adopted its first-reading position on 16 December 2025 by 428 votes to 218, with 17 abstentions (T10-0324/2025). After the Council's adoption, the act was signed in Brussels on 24 February 2026, and the twentieth-day rule of Article 6 fixed entry into force: publication on 26 February 2026 put it at 18 March 2026.

The eight dated steps from the proposal to the transposition deadline are listed in Table 1.

The authentic text of Directive (EU) 2026/470 (CELEX 32026L0470) is published on EUR-Lex, and the procedure record is held in the European Parliament's Legislative Observatory.

What Omnibus I Changed in the Reporting Rules

Omnibus I changed the CSRD through numbered provisions of Directive (EU) 2026/470 on the size test, the end of wave 1, listed SMEs, non-EU groups, the value-chain cap, assurance, sector standards, the ESRS mandate, a standard for voluntary use and digital mark-up. Table 2 maps each change to its amending provision, the rule before Directive (EU) 2026/470 and the rule after it. The size values in the "before" column are those of Delegated Directive (EU) 2023/2775, which raised the size criteria of the Accounting Directive for inflation from financial year 2024. Each change reaches companies through the national law that transposes it.

The New Size Test: Two Thresholds for Undertakings and Groups

From financial years starting on or after 1 January 2027, an undertaking reports only if it has a net turnover of more than EUR 450 million and an average of more than 1,000 employees during the financial year, both conditions together (Article 19a(1) of Directive 2013/34/EU as replaced by Article 2(4)(a) of Directive (EU) 2026/470). A parent undertaking applies the same two values to its group on a consolidated basis (Article 29a(1), as replaced by Article 2(5)(a)). The balance-sheet criterion and the two-of-three test no longer decide CSRD scope.

Issuers under the Transparency Directive 2004/109/EC follow the same values from financial year 2027, on an individual or consolidated basis (CSRD Article 5(2), third subparagraph, as amended by Article 3(1)(b) of Directive (EU) 2026/470). How both values are counted, from the employee average to net turnover, is set out under CSRD thresholds after the Omnibus.

What Happens to First-Wave Reporters in FY 2025 and FY 2026

Wave 1, the large public-interest entities and public-interest parents with more than 500 employees that reported from financial year 2024, now covers financial years 2024 to 2026 only (CSRD Article 5(2)(a) as amended by Article 3(1)(a)(i) of Directive (EU) 2026/470). From financial year 2027, a former wave-1 undertaking that does not exceed both new values falls outside the scope (recital 31).

Article 3(1)(c) added a Member-State option for financial years starting between 1 January 2025 and 31 December 2026: Member States may exempt undertakings or issuers not exceeding EUR 450 million net turnover or an average of 1,000 employees, on a consolidated basis where applicable. The ESRS quick fix, Delegated Regulation (EU) 2025/1416, in force since 13 November 2025, already spared wave-1 undertakings from reporting additional information for financial years 2025 and 2026 compared with financial year 2024 (recital 4).

Listed SMEs Removed from the Reporting Regime

Listed SMEs, the former third wave, are no longer in the CSRD regime: Directive (EU) 2026/470 deleted Article 29c on the listed-SME standards (Article 2(7)), the opt-out in Article 19a(6) and (7) (Article 2(4)(c)) and CSRD Article 5(2)(c) (Article 3(1)(a)(iii)). Before Directive (EU) 2026/470, listed SMEs other than micro-undertakings fell under Article 19a(1), with their own standard (Article 29c) and an opt-out for financial years starting before 1 January 2028. With Article 19a(1) as replaced by Article 2(4)(a), which sets a size test only, no listed-SME reporting date remains in the CSRD. The Stop-the-clock Directive had only moved the third wave to financial year 2028; Omnibus I removed it. A listed SME that wants to report on sustainability now has a voluntary route: the voluntary standard (VS, formerly VSME), adopted under Article 29ca of Directive 2013/34/EU for undertakings with up to 1,000 employees.

Non-EU Groups: New EU Turnover Values for the Group Report

A third-country group reports under Article 40a(1) of Directive 2013/34/EU, as amended by Article 2(13) of Directive (EU) 2026/470, when its Union net turnover exceeds EUR 450 million in each of the last two consecutive financial years and it has an EU subsidiary or branch with net turnover above EUR 200 million in the preceding financial year. The EU subsidiary or branch publishes that group report.

The first financial year stays the one starting on or after 1 January 2028 (CSRD Article 5(2), second subparagraph). The standards for these reports are a Commission delegated act under Article 40b, for which Directive (EU) 2024/1306 had set 30 June 2026, and EFRAG has published an exposure draft for them, ESRS-40a, for public consultation.

Assurance Stays at the Limited Level

Sustainability reporting keeps limited assurance only: Article 34(1)(aa) of Directive 2013/34/EU, as replaced by Article 2(12)(a) of Directive (EU) 2026/470, no longer foresees a move to reasonable assurance, and the empowerment for reasonable-assurance standards was removed (recital 5). Before Directive (EU) 2026/470, Article 26a(3) of the Audit Directive had required the Commission to adopt reasonable-assurance standards by 1 October 2028, after a feasibility assessment; that date was a Commission deadline, never a reporting date for companies.

The EU limited-assurance standard is due as a Commission delegated act by 1 July 2027 (Article 26a(3) of Directive 2006/43/EC as replaced by Article 1(3) of Directive (EU) 2026/470), instead of 1 October 2026 before Directive (EU) 2026/470. That standard is not adopted as of 29 October 2026. How ISSA 5000 and the CEAOB guidelines fit in beside the future EU act is covered under sustainability assurance standards.

The assurance opinion must also respect the right of protected undertakings to decline requests for information beyond the voluntary standard (Article 34(2a) of Directive 2013/34/EU, as amended by Article 2(12)(b) of Directive (EU) 2026/470).

Standard-Setting Powers after Omnibus I: Sector Set Deleted, Revision Ordered

Directive (EU) 2026/470 deleted the Commission's power to adopt sector-specific ESRS (Article 29b(1) third, fourth and sixth subparagraphs, deleted by Article 2(6)(a)), whose first set had been due by 30 June 2026 under Directive (EU) 2024/1306, and in recital 18 it committed the Commission to revise the first set of ESRS within six months of entry into force. The sector empowerment is deleted, not postponed: no date for sector standards remains in the Accounting Directive.

Recital 18 names six aims for that revision: removing datapoints, prioritising quantitative datapoints, distinguishing mandatory from voluntary datapoints, clearer instructions on materiality, consistency and interoperability. Article 29b(2), first subparagraph as replaced, now requires the standards to prioritise quantitative information. Article 29ca, inserted by Article 2(8), empowers the Commission to adopt standards for voluntary use by 19 July 2026, based on Recommendation (EU) 2025/1710 "in its original version" and reviewed at least every four years with EFRAG's technical advice. The Commission met both mandates on 3 July 2026, as the delegated acts below show.

Smaller Changes in the Accounting and Audit Directives

Smaller changes complete the reporting side of Omnibus I: new omission grounds, two group options, a narrower duty on key intangible resources, an inflation review of the new values and new audit-side rules. The four omission grounds of Article 19a(3) of Directive 2013/34/EU, as amended by Article 2(4)(b)(iii) of Directive (EU) 2026/470, are listed below.

• Seriously prejudicial information, in exceptional cases and under the conditions of the article.
• Trade secrets within the meaning of Directive (EU) 2016/943.
• Classified information under Regulation (EU) 2023/2418.
• Information protected by other Union or national law, or for reasons of privacy or security.

An undertaking that relies on a ground discloses that it has done so and reassesses the omission at each reporting date. Article 29a(4a) lets a group leave out acquired or merged undertakings for that financial year, and subsidiaries leaving the group, with significant events indicated. Article 29a(7a) lets a financial holding parent with independent subsidiaries choose not to report consolidated information. The duty to report key intangible resources in Article 19(1) now applies only to undertakings above the new values (Article 2(3)).

The inflation review of Article 3(13), at least every five years, now also covers the values in Articles 19(1), 19a(1), 29a(1) and 40a(1). On the audit side, an audit firm assuring sustainability reporting designates at least one key sustainability partner approved as statutory auditor, who may be the key audit partner (Article 24b(1) of Directive 2006/43/EC as replaced by Article 1(2)). Third-country auditors gain a transitional regime for assurance reports on financial years starting between 1 January 2025 and 31 December 2030 (Article 45(5b), inserted by Article 1(4)(b)).

What Omnibus I Did Not Change

Omnibus I kept the core of the CSRD: double materiality, a sustainability statement in the management report, the 12 ESRS (in the 2023 set and in the 2026 set), limited assurance and a first non-EU financial year of 2028. The 12 standards are ESRS 1, ESRS 2, E1 to E5, S1 to S4 and G1, in both Delegated Regulation (EU) 2023/2772 and Delegated Regulation (EU) 2026/1563.

An undertaking that exceeds both values still runs a double-materiality assessment, reports its sustainability information in the management report under Article 19a(1) and obtains limited assurance on it. The Omnibus changed who reports and from which financial year, not these three steps. The steps themselves are laid out under CSRD compliance after the Omnibus.

The Two Delegated Acts of 3 July 2026

The Commission completed Omnibus I with two delegated acts adopted on 3 July 2026: Delegated Regulation (EU) 2026/1563 with the revised (simplified) ESRS, which enters into force on 10 November 2026 and is mandatory for financial years beginning on or after 1 January 2027, and Delegated Regulation (EU) 2026/1560 with the voluntary standard, in force since 24 September 2026. Both were published in the Official Journal on 21 September 2026.

Delegated Regulation (EU) 2026/1563 (C(2026) 5010) replaces Annexes I and II of Delegated Regulation (EU) 2023/2772 and does not repeal it (Article 1). Undertakings reporting for financial year 2026 may choose which version they apply and must state that version (Article 2).

Delegated Regulation (EU) 2026/1560 (C(2026) 5011) holds the voluntary standard in Annex I and the value-chain list in Annex II; the value-chain cap applies from financial years beginning on or after 1 January 2027 (Article 4). Recommendation (EU) 2025/1710 no longer produces legal effects since 24 September 2026 (recital 5).

The two acts compare as shown in Table 3.

The Sustainability Omnibus in Depth: Two Detailed Pages

Two parts of Omnibus I have their own pages here: the Stop-the-clock Directive (EU) 2025/794, which moved the CSRD reporting dates first, and the value-chain cap, which limits what in-scope companies may ask of protected undertakings. Table 4 lists both pages with the question each answers.

Where Omnibus I Stands on 2026-10-29

As of 29 October 2026, Directive (EU) 2026/470 has been in force since 18 March 2026, Member States have until 19 March 2027 to transpose Articles 1 to 3, the revised ESRS enter into force on 10 November 2026, and the EU limited-assurance standard is not adopted (due by 1 July 2027).

The next dated steps after 29 October 2026 are listed below in date order.

• 10 November 2026: Delegated Regulation (EU) 2026/1563 enters into force (Article 3).
• 1 January 2027: first financial years under the new size test; the revised ESRS become mandatory; the value-chain cap of Annex II of Delegated Regulation (EU) 2026/1560 applies.
• 19 March 2027: transposition deadline for Articles 1 to 3 of Directive (EU) 2026/470 (Article 5(1)).
• 1 July 2027: deadline for the EU limited-assurance standard (Article 26a(3) of Directive 2006/43/EC).
• 1 January 2028: first financial years for the Article 40a group report of non-EU groups.
• 19 March 2028: Commission report on technological solutions for sustainability reporting (Article 29f of Directive 2013/34/EU, inserted by Directive (EU) 2026/470).
• 30 April 2029: Commission review reports under points (a), (b), (d) and (e) of CSRD Article 6(1), as amended by Article 3(2) of Directive (EU) 2026/470.
• 30 April 2031: Commission report on extending the scope (point (c)), including undertakings at or below the new values and third-country undertakings without an EU subsidiary or branch, followed by reports every three years.

National law decides when the new rules bind a company, so the dated status of each Member State belongs to its country page, not to this summary of the EU act. Each Member State's law is followed in the tracker of Omnibus I laws in the 27 Member States and Norway.

What the Sustainability Omnibus Is Not

The sustainability Omnibus is not a new regulation, not a repeal of the CSRD and not an official list of reporting companies: it is an amending directive that Member States must write into national law. The three questions below separate it from the acts around it.

Does Omnibus I Apply Directly to Companies?

No: Directive (EU) 2026/470 is addressed to the Member States (Article 7), and its CSRD changes reach companies only through national law transposing Articles 1 to 3 by 19 March 2027. The CSRD, Directive (EU) 2022/2464, works the same way.

The delegated regulations 2026/1563 and 2026/1560 are different: they apply directly in every Member State, without transposition. The amended text of the CSRD can be read in the CSRD consolidated version after the Omnibus. EUR-Lex holds two consolidated versions, dated 17 April 2025 (after the Stop-the-clock Directive) and 18 March 2026 (after Directive (EU) 2026/470); consolidated versions are documentation tools without legal effect, and only the texts published in the Official Journal are authentic.

Is There an Official Count of Companies Still Reporting?

No: Directive (EU) 2026/470 gives no official count of the companies in scope after the Omnibus, and no official figure for the final values exists. The Commission's FAQ notice C/2024/6792 (OJ C, 13 November 2024) predates the Omnibus, so its answers on listed SMEs and on the size values are not current law. A company therefore checks its own net turnover and employee average against Article 19a(1), or its group's against Article 29a(1), instead of relying on a published total.

Which Date Counts: Publication or Entry into Force?

Entry into force counts: Directive (EU) 2026/470 was published on 26 February 2026 and entered into force on the twentieth day after publication, 18 March 2026 (Article 6). The transposition deadline one year later, 19 March 2027 (Article 5(1)), is a different date: it is the day by which national law must carry Articles 1 to 3. The first financial year under the new size test is a third date, the one starting on or after 1 January 2027.