EU Omnibus
An EU simplification package; Directives (EU) 2025/794 and 2026/470 changed CSRD scope and CSDDD timing and scope, and the ESRS were revised.
Editorial definition: The QHSE Standard, updated 3 October 2026 · https://qhsetech.com/glossary/eu-omnibus
Scope: Check each adopted instrument and its effective dates; the umbrella label does not make all proposals law.
Sources checked: . Examples are editorial illustrations.
What the Omnibus I instruments adopted into law say
Omnibus is the label for the Commission's simplification package of 26 February 2025. Its sustainability part proposed to limit the CSRD to the largest companies, meaning above 1,000 employees, and to stop reporting duties on large companies from burdening smaller companies in their value chains. Two instruments have since been adopted. The first is the stop-the-clock Directive (EU) 2025/794 of 14 April 2025, published on 16 April 2025, which moved the start of reporting for later groups of companies to financial years starting from 1 January 2027 and from 1 January 2028 and shifted the due diligence timetable. The second is Directive (EU) 2026/470, which was adopted on 24 February 2026, published on 26 February 2026 and entered into force on 18 March 2026.
Directive (EU) 2026/470 amends the audit directive, the Accounting Directive, the 2022 amending directive (the CSRD) and the due diligence directive. It replaces the earlier size tests with one rule: the reporting duty applies to undertakings, and to groups on a consolidated basis, above both a net turnover of EUR 450,000,000 and an average of 1,000 employees. For third-country groups it uses EUR 450,000,000 of net turnover in the Union at group level, with EUR 200,000,000 for a subsidiary or branch. It protects value-chain undertakings of up to 1,000 employees with a right to decline requests above the voluntary standard, and it removes the Commission's power to adopt sector-specific standards, leaving room for sector guidance. It requires limited assurance standards by 1 July 2027, drops the requirement for reasonable assurance standards, and lets Member States exempt undertakings outside the new scope for financial years that start from 1 January 2025 to 31 December 2026. Member States must bring the reporting amendments into force by 19 March 2027 and the due diligence amendments by 26 July 2028.
Two delegated acts followed on 3 July 2026 and were published on 21 September 2026: the revised ESRS and the standard for voluntary use. The Commission page opened for this entry describes the package as a simplification of EU rules, and the label does not mean every proposal in it became law. Parts of the package outside sustainability reporting and due diligence were not checked for this page. Transposition, national choices on exemptions and later guidance decide what a given company must do, so confirm the law of the Member State and the period. This page gives general information only and is not legal advice on a company's reporting position.
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What an Omnibus tracking record holds in software
- Each instrument relied on, with its number, adoption date, publication date and date in force.
- The size test inputs by year and entity: average employees, net turnover, group or entity level, and the source.
- The Member State laws that apply, their status and the date it was checked.
- The standards edition and delegated act used for each reporting period.
- Value-chain information requests received and sent, with the size self-declaration and the limit applied.
- Decisions taken because of the changes, such as pausing a data project, with date and owner.
Omnibus, stop-the-clock and the later delegated acts
The stop-the-clock directive changed dates only. Directive (EU) 2026/470 changed scope and content and needs national laws before it applies to a company. The July 2026 delegated acts change the standards and have their own dates. Using Omnibus for all of these at once hides which date belongs to which instrument.
A hypothetical example: a dated tracker for three entities
The entities below are invented, and the case describes no real company. A group tracks three entities. Entity A has 1,100 employees and EUR 500 million of net turnover, so it is above both amended limits, 1,100 against 1,000 and 500 against 450. Entity B has 900 employees and EUR 600 million, so it is below the employee limit. Entity C has 1,300 employees and EUR 400 million, so it is below the turnover limit. On the figures alone only entity A is in mandatory scope.
The tracker also records that Directive (EU) 2026/470 is in force, that national laws are due by 19 March 2027 and that the Member State has not yet published its law, so each entry carries a review date. Entity B supplies a customer in scope. Its team files the customer's request beside the limit in the voluntary standard and marks which items fall above it. When the national law appears, each entry is re-checked, not assumed.
Common misunderstandings about the Omnibus
- Omnibus is not one law. It is a label for a package, and a proposal is not law.
- The stop-the-clock directive did not remove the CSRD. It moved dates, and the later directive changed scope.
- In force is not the same as applying to a company. The reporting changes entered into force on 18 March 2026, but national laws are due by 19 March 2027.
- Companies outside the new scope are not free of data requests, but a protected undertaking may decline what exceeds the voluntary standard.
- Simpler does not mean unassured. The directive still sets 1 July 2027 for limited assurance standards.
How the Omnibus relates to other glossary terms
The Omnibus instruments changed the rules around reporting and due diligence rather than the underlying topics.
- CSRD: the reporting directive whose scope and standards the package changed.
- CSDDD: the due diligence directive amended in the same instrument with later dates.
- ESRS: the standards revised by the delegated act of 3 July 2026.
- VSME: the voluntary standard that became the basis of the EU standard and value-chain cap.
Records and evidence that usually exist for Omnibus tracking
- The Official Journal text of each instrument and any consolidated version.
- Headcount and turnover records for the size test, with the method for averaging employees.
- A dated note recording the conclusion on scope and who reached it.
- Records of national transposition checks.
- Customer data requests and the replies sent.
- Minutes of decisions taken because of the changes.
What a software tool needs to capture for the Omnibus
- A register that lists each instrument with its dates and status and flags the next date.
- A size-test calculation that holds inputs by year and entity and shows which limit is exceeded.
- Country fields for transposition status, with a review date.
- A link between each datapoint or process and the instrument that requires it, so a change shows what it touches.
- A request log for value-chain information with the size declaration and limit applied.
- Alerts for dated milestones, without presenting them as legal advice.
- Change history for any decision that relied on a text later changed.
Catalog profiles documenting CSRD reporting workflows
Profiles are listed by the CSRD workflow rule. Being listed does not mean a product tracks national transposition or applies the amended thresholds; ask in a demonstration.
Same rule for every product: tagged “ESG Reporting”, “ESG Frameworks Reporting”, “Sustainability Reporting”, “Materiality Assessment”, “ESG & Sustainability” or “Sustainability & ESG”, with a sourced CSRD, ESRS or materiality capability in its record, or one the vendor stated to us, labelled as vendor-stated. Documented and conditional capabilities qualify; check the linked scope before treating a module as included.
Tekmon pays for a sponsored placement (above); its place in this list follows the same rule as every entry. How lists are ordered
Dunya Analytics · ESRS E4, GRI, CDP and SBTN aligned reports · Conditional
Vendor source · Profile checked
osapiens HUB · Reporting and disclosure preparation · Conditional
Vendor source · Profile checked
Datamaran · Materiality thresholds and borderline review · Documented
Vendor source · Profile checked
NatureMetrics · TNFD, ESRS E4 and GRI reporting support · Conditional
Vendor source · Profile checked
Normative · ESG disclosure collection · Conditional
Vendor source · Profile checked
Novisto · Double-materiality assessment · Conditional
Vendor source · Profile checked
Persefoni · Disclosure review record · Documented
Vendor source · Profile checked
Plan A · CSRD Manager · Conditional
Vendor source · Profile checked
Position Green · Double materiality assessment · Documented
Vendor source · Profile checked
Sweep · Multi-framework sustainability reporting · Documented
Vendor source · Profile checked
XNatura · ESRS E4, TNFD and GRI disclosure packs · Conditional
Vendor source · Profile checked
Tekmon · Stakeholder materiality questionnaires and matrix · Documented
Vendor source · Profile checked
Enablon · ESG data, reporting and double materiality · Conditional
Vendor source · Profile checked
VelocityEHS · GHG and materiality · Documented
Vendor source · Profile checked
All 14 matching profiles are shown. Documentation review, not hands-on testing or a claim of compliance.
Related software
Frequently asked questions
Is the Omnibus now law?
The parts that have been adopted are law: Directive (EU) 2025/794 and Directive (EU) 2026/470, each with its own dates. The label also covers proposals, so check each instrument rather than the name.
When must Member States apply the 2026 changes?
Directive (EU) 2026/470 asks Member States to bring the reporting and assurance amendments into force by 19 March 2027 and the due diligence amendments by 26 July 2028. National laws set the exact application, so check the Member State.
Did the Omnibus change who has to report under the CSRD?
Yes. Directive (EU) 2026/470 limits the duty to undertakings above both a net turnover of EUR 450,000,000 and an average of 1,000 employees, and lets Member States exempt others for financial years that start from 1 January 2025 to 31 December 2026.
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Related guides
- ESRS Disclosures 2026: A Practical Implementation Guide
Article on ESRS disclosures.
- CSRD Data Readiness: An Evidence Checklist
Evidence checklist for CSRD data readiness.
- Supply Chain Due Diligence Software: Scope to the Law in Force
Software guide on supply chain due diligence.