CSRD Omnibus Simplification Package: What Changed and What It Means for Your Reporting Obligations

If you started your CSRD project in 2024, the rulebook you planned against is no longer the rulebook you're reporting under. The EU's Omnibus Simplification Package, first proposed in February 2025 and finalised through a series of follow-up acts in late 2025 and early 2026, has materially reshaped who must report, when they must report, and how much they must disclose.

For some companies, the Omnibus is a reprieve — they're now out of scope or have an extra two years to prepare. For others, it's a quiet trap: the headline simplifications don't apply, but the goalposts on data quality, assurance, and transition plans have moved.

This guide walks through what actually changed, what stayed the same, and how to recalibrate your CSRD project — with concrete pointers on where a specialist CSRD consultant earns their fee right now.

What Is the Omnibus Simplification Package?

The Omnibus is a bundle of legislative proposals from the European Commission designed to reduce the cumulative reporting burden of three pieces of EU sustainability legislation:

The Corporate Sustainability Reporting Directive (CSRD) — see our overview of CSRD
The Corporate Sustainability Due Diligence Directive (CSDDD)
The EU Taxonomy Regulation

The political driver was clear: complaints from EU industry, member-state finance ministries, and the European Council that compliance costs — particularly for mid-sized companies in Wave 2 — were disproportionate to the policy benefit. The Commission's response was the Omnibus, which moves on three tracks:

Stop-the-Clock Directive — postpones reporting deadlines for Waves 2 and 3
Substantive Directive — narrows the scope of who is in CSRD at all and trims the ESRS data requirements
Delegated Acts — revises ESRS Set 1 to remove redundant or low-value disclosures and postpones sector-specific standards

The combined effect is the largest re-scoping of EU sustainability reporting since the CSRD was adopted in 2022.

The Stop-the-Clock Directive: New Reporting Deadlines

The simplest and fastest piece of the Omnibus to land was Directive (EU) 2025/794, commonly called "Stop the Clock." Adopted in April 2025, it pushed back reporting deadlines without yet changing scope:

Wave	Original first report	Revised first report
Wave 1 (large public-interest entities, 500+ employees)	FY 2024 (reported 2025)	Unchanged — already filed
Wave 2 (other large companies)	FY 2025 (reported 2026)	FY 2027 (reported 2028)
Wave 3 (listed SMEs)	FY 2026 (reported 2027)	FY 2028 (reported 2029)
Wave 4 (non-EU companies €150M+ EU revenue)	FY 2028 (reported 2029)	Unchanged

If your company was preparing as a Wave 2 reporter, you now have an additional two financial years to build data systems, run a double materiality assessment, and design your internal controls. That breathing room is real — but it should not be confused with a pause. The substantive scope changes (below) determine whether you'll need to file at all.

Substantive Scope Changes: Higher Thresholds

The Substantive Directive — politically the most contested piece of the Omnibus — raises the size thresholds for CSRD applicability significantly. The Commission's stated goal was to align CSRD with the larger-company focus of the CSDDD and remove "long tail" reporters whose marginal contribution to investor information was deemed low.

New Wave 2 Thresholds

Under the original CSRD, "large undertakings" were defined as companies meeting two of three criteria:

250+ employees
€50M+ net turnover
€25M+ total assets

The Omnibus raises the employee threshold for in-scope companies to 1,000 employees, and increases the turnover criterion to €450M. The result, according to Commission impact estimates, is roughly an 80% reduction in the number of in-scope companies compared with the original CSRD.

Listed SMEs (Wave 3) — Reporting Made Voluntary

Listed SMEs — originally Wave 3 — are removed from mandatory CSRD scope under the substantive proposal and pointed instead toward the Voluntary SME standard (VSME). We cover the VSME and the new realities for SMEs in this guide.

This is a major shift: many smaller listed companies that had already started CSRD readiness work now have a choice — continue voluntarily (often the right answer if larger customers are demanding ESG data) or pivot to the lighter VSME framework.

What Is Unchanged

Wave 1 (the largest public-interest entities) remains in scope with no relief on disclosures already made.
Wave 4 (non-EU undertakings with €150M+ in EU turnover) remains in scope with the original 2029 first-reporting date.
The principle of double materiality is preserved.
The legal basis for mandatory limited assurance, transitioning to reasonable assurance, is preserved — see our CSRD assurance guide.

ESRS Revisions: Fewer Data Points, Same Architecture

In parallel with the directive-level changes, EFRAG was asked to deliver a revised version of ESRS Set 1 with the explicit goal of cutting the number of mandatory disclosures.

The revised standards — adopted via delegated act in early 2026 — introduce changes in three categories:

1. Reduced Data Point Count

EFRAG removed or made voluntary a substantial share of the original ~1,100 data points. The cuts target:

Narrative disclosures with low decision-usefulness for investors
Disclosures already covered by financial reporting under IFRS or national GAAP
Granular, low-priority data in topical standards (e.g. detailed biodiversity sub-metrics)

The architecture of the 12 ESRS standards remains unchanged. ESRS 1, ESRS 2, the five environmental standards (E1–E5), four social standards (S1–S4), and one governance standard (G1) all continue. What changed is the content and conditional logic within each.

2. Stricter Materiality Filter

The revised ESRS 1 makes clear that non-material topics do not require disclosure beyond a brief explanation of why they are not material. The previous "rebuttable presumption" language around climate (ESRS E1) is softened: companies must still consider climate material in nearly all cases, but the documentation burden for non-material topics is reduced.

A robust double materiality assessment is therefore even more important — it now does more work in justifying what you do not report.

3. Value Chain Cap

One of the most painful aspects of the original ESRS was the open-ended requirement to gather data from upstream and downstream value-chain partners. The revised standards introduce a value chain "cap" — companies are not required to obtain data from value-chain partners with fewer than 1,000 employees and below specified turnover thresholds, except in narrowly defined circumstances.

This is a meaningful relief for companies struggling with Scope 3 emissions data collection from SME suppliers, but it does not eliminate the obligation to disclose the value chain itself, the methodology used, and any material risks identified.

4. Sector-Specific Standards Postponed

The sector-specific ESRS — originally planned for 2026 adoption — are postponed indefinitely under the Omnibus. EFRAG's resources are redirected first to consolidating the revised cross-cutting standards.

If you operate in oil & gas, coal, mining, road transport, or another sector that was expecting tailored disclosures, the cross-cutting ESRS continue to apply, and you should follow general industry guidance — see our CSRD industry sector guide.

CSDDD and Taxonomy Changes (Briefly)

The Omnibus also touches the CSDDD (postponing first application from 2027 to 2028, narrowing the chain-of-activities concept to "tier 1" suppliers, and reducing penalty harmonisation) and the EU Taxonomy (raising the threshold for mandatory Taxonomy reporting to align with the new CSRD scope, and simplifying KPI reporting templates for non-financial undertakings).

These changes interact with CSRD reporting in important ways: a company that drops out of mandatory CSRD scope will, in most cases, also drop out of mandatory Taxonomy KPI reporting. But supply-chain pressure from in-scope customers will continue to flow downstream.

Are You Still In Scope? A Decision Framework

The simplest way to recalibrate after the Omnibus is to walk through four questions:

1. Were You Already Filing as a Wave 1 Reporter?

If yes, you remain in scope and your obligations are largely unchanged for FY 2025 reporting. Focus on continuous improvement: tightening internal controls, expanding data automation, and preparing for the transition to reasonable assurance.

2. Are You a Large Group Above the New Thresholds (1,000+ Employees and €450M+ Turnover)?

If yes, you are still in mandatory scope as a Wave 2 reporter, with a first report on FY 2027. Use the additional time well — invest in data infrastructure, governance, and a complete double materiality assessment before the deadline tightens again.

3. Did You Fall Below the New Thresholds?

If yes, you have three real options:

Stop reporting work entirely. Possible, but rarely optimal — your bank, large customers, and insurers may still demand ESG data.
Continue reporting voluntarily under ESRS. Useful if you operate in a heavily ESG-scrutinised sector or want to stay aligned with parent-company expectations.
Switch to the VSME standard. A proportionate framework designed exactly for this situation. See our SME compliance guide.

4. Are You a Non-EU Group With €150M+ EU Revenue?

Wave 4 timing is unchanged — first report on FY 2028. But the Omnibus simplifications to ESRS Set 1 will apply to your report when you file. If your group has been waiting to start, now is when most consultants would tell you to begin scoping.

What the Omnibus Means If You're Hiring a CSRD Consultant

The Omnibus did not reduce the demand for CSRD expertise — if anything, it sharpened it. The new realities favour consultants who can:

Re-scope your project against the new thresholds. Many companies have already invested in materiality work and data systems that no longer match their actual obligations. A good consultant will help you decide what to keep, what to defer, and what to retire.
Translate the revised ESRS into a concrete data model. The reduced data point count is helpful only if you know which points apply to your business. This is a core area where hiring an experienced CSRD consultant saves months of internal debate.
Manage the value chain cap practically. The new SME exemption changes how you collect Scope 3 emissions data — but it does not relieve you of disclosing methodology and assumptions.
Bridge to assurance under the new standards. Auditors are still figuring out how to apply limited assurance to the revised ESRS. Consultants who have run engagements on both versions of the standard are disproportionately valuable right now.

If you're scoping a project, expect consultant fees to remain stable or increase modestly: the work is no smaller than before, just better targeted. Beware of providers offering large discounts on the basis that "it's all simpler now" — the simplifications are uneven, and the assurance bar has not dropped.

For larger organisations weighing their options, our comparison of Big 4 versus independent CSRD consultants remains directly relevant; if anything, the Omnibus has widened the appeal of specialist boutiques that can move fast on the revised standards.

Common Mistakes Companies Are Making Right Now

From conversations with CSRD project leads in the months since the Omnibus was finalised, four recurring missteps stand out:

Treating the delay as a stop. Companies that paused their data collection in mid-2025 are now scrambling for FY 2027 baselines they should have been capturing all along.
Assuming "out of scope" means "no ESG reporting needed." Customers, banks, and insurers continue to demand ESG data regardless of CSRD applicability.
Discarding double materiality work. The methodology of the original assessment is still valid — only the disclosure obligations changed. Re-running materiality from scratch is wasteful.
Over-trimming disclosures. A defensive auditor will still expect more, not less, narrative around omitted data points. The revised ESRS is not an invitation to minimal reporting.

If any of these sound familiar, the cost of a short, targeted advisory engagement to recalibrate is almost always less than the cost of an Omnibus-driven false start.

Timeline Summary

Date	Event
Feb 2025	European Commission publishes the Omnibus Simplification Package
Apr 2025	Stop-the-Clock Directive adopted — Wave 2 and Wave 3 deadlines postponed
Late 2025	Substantive Directive adopted — new thresholds for in-scope companies
Early 2026	Revised ESRS Set 1 adopted via delegated act
2026	National transposition of substantive changes by member states
FY 2027	First reporting period for revised Wave 2 (reports filed in 2028)
FY 2028	Wave 4 (non-EU groups) first reporting period

Next Steps

If you're a CSRD project lead, sustainability manager, or CFO trying to make sense of the post-Omnibus landscape, do three things this quarter:

Run a 2-week scope review. Confirm whether the new thresholds change your status. Document the conclusion in a board-ready memo.
Refresh — don't restart — your materiality assessment. Map the original output to the revised ESRS data points and identify what is genuinely no longer required.
Talk to a specialist. Whether internal or external, you need someone with hands-on experience in both the original and revised ESRS to avoid the most expensive mistakes. Browse our directory of CSRD experts for consultants who have worked on Wave 1 reports and are now advising Wave 2 companies through the transition.

The Omnibus did not make CSRD easier. It made it more proportionate — and the companies that adapt their projects fastest will be the ones that turn the simplification into a competitive advantage rather than a missed signal.