Insight

CSRD, rewritten: Omnibus I passes, more relaxation ahead?

Hot off the EU legislative press: the Corporate Sustainability Reporting Directive (CSRD) just got a makeover. Branded as part of the EU’s "Omnibus I" package and dubbed by some as the "Stop-the-Clock" move, this new directive—passed by the European Parliament and Council—delivers a notable shift in sustainability reporting obligations. For some, it’s welcome relief. For others, it feels like déjà vu: the CSRD was already negotiated, agreed, and (in many countries) transposed. So why dilute now? And what’s next—Omnibus II: The Relaxening?

CSRD, revisited: what’s in Omnibus I?
Omnibus I folds together a set of revisions aimed at reducing the administrative burden of sustainability reporting, especially for companies not yet reporting. It postpones reporting timelines, raises the size thresholds for who must report, eases data point requirements, and postpones the introduction of sector-specific standards—indefinitely. Some countries—like Sweden—had already transposed the CSRD. Others, including the Netherlands, hadn’t. Regardless, many companies had already invested in the process. Among Tangelo’s client base alone, around 50 companies reported under CSRD for the first time this year—introducing a sustainability statement in their 2024 annual report using the ESRS, regardless of whether their national law required it yet. And many of the large companies we work with who now fall under the ‘delayed’ group? They're not delaying.

Meanwhile, Omnibus I may not be the final word. With Omnibus II likely on the horizon, even more ‘streamlining’ could be in store.

The main changes: a clear(er) breakdown

Category

Thresholds

Timing

Reporting standard

Listed companies & PIEs (NFRD legacy)

No change

First report for FY2024 (published 2025)

ESRS (mandatory)

Large companies (revised thresholds)

> 1,000 employees and either > €50m turnover or > €25m assets (aligned with CSDDD)

First report for FY2027 (published 2028)

ESRS (mandatory)

Listed SMEs

< 250 employees, listed on EU-regulated market

First report for FY2026 (published 2027), with option to defer to FY2028 (published 2029)

ESRS for listed SMEs (a simplified subset of ESRS)

Other SMEs

Voluntary only

VSME standard expected to be available from 2027

VSME (voluntary simplified ESRS)

Non-EU parent companies (CSRD Article 40)

€150m+ EU turnover and at least one large or listed EU subsidiary/branch

First report for FY2028 (published 2029)

ESRS (consolidated at group level)


Simplification, not abandonment

  • Revised scope and thresholds: The increase in size thresholds means an estimated 80% fewer companies will be subject to CSRD than previously expected—though these exempted companies represent only a small fraction of total EU market capitalization.
  • Adjusted timelines: The key delays apply to large companies not already reporting and listed SMEs. However, many companies continue on schedule, especially those already investing in governance, data, and reporting tools.
  • Simplification of disclosures: Fewer mandatory data points for the initial years. Companies can omit disclosures they deem not material without explanation. Sector-specific ESRS have been postponed indefinitely. The updated ESRS with reduced datapoints will apply starting from reports on fiscal year 2025. A simplified voluntary ESRS for SMEs (VSME) is expected to be published in 2026 and available for use in 2027.
  • Audit and assurance requirements: The level of assurance will remain limited, with no move to reasonable assurance—for now. This significantly reduces the audit burden. Limited assurance involves a review-level engagement (is the information plausible and free from obvious error?), whereas reasonable assurance requires deeper substantiation and internal control checks.

Crucially, double materiality remains the foundation—companies must still assess both impact and financial materiality. But they no longer need to justify the omission of disclosures deemed not material.

And no, foreign companies are not off the hook

Omnibus I made no changes to Article 40. Non-EU companies with significant EU activity still need to report, starting from fiscal year 2028. The only relaxation here is a slight reduction in the required data points.

These companies must apply the ESRS, but at the level of the non-EU parent company—not at the level of the EU subsidiary or branch. The sustainability disclosures must be included in a consolidated report covering the entire global group. That report must be made publicly available and meet EU filing and assurance requirements.

If you’re running a global group with major EU presence, it’s time to prepare.

Implementation timeline for member states

EU member states must transpose the changes introduced by Omnibus I into national legislation by December 31, 2025. This gives them time to update their frameworks in line with the revised CSRD requirements and timelines.

What now?

For all the fanfare, Omnibus I is a reset—not a reversal. CSRD is still happening. ESRS are in force. And pressure on companies to communicate clearly and credibly about sustainability has only increased. The difference is: you now have more time—if you want it.

At Tangelo, we continue to help companies take control of their corporate reporting with a smart, end-to-end platform. We integrate your ESG efforts seamlessly: bring policies, data, and strategy together in your annual report, manage compliance checks, and publish across multiple channels. And yes, we offer fully integrated tagging of CSRD/ESRS disclosures for ESEF and SBR (for our Dutch clients).

So, while the clock may have stopped, the reporting work hasn’t.

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