The CSRD after the Omnibus: what changed, and for whom

The Corporate Sustainability Reporting Directive (CSRD) is the European rule for sustainability reports. At first, all large companies from about 250 employees would fall under it, as well as listed SMEs. That has changed.

What changed

In early 2026 the European Union published the Omnibus packageSource: Linklaters, Sustainable Futures, Checked. The CSRD now only applies to large companies. They have more than 1,000 employees and more than €450 million in turnoverSource: Europees Parlement en Raad van de Europese Unie, Not yet checkedSource: Linklaters, Sustainable Futures, Checked. Both must be true. Companies that did not report yet start with financial year 2027 at the earliest.

For companies below that line, the duty goes away. The standards for the report, the European Sustainability Reporting Standards (ESRS), also get fewer data points. The Netherlands must put the new rules into national law by March 2027Source: Linklaters, Sustainable Futures, Checked. So details can still shift.

If you are large

If you are still in scope, the work stays, but with fewer data points. You still need a sound materiality assessment, and a trail from source to report. Your auditor must be able to follow your choices.

If you have just dropped out of scope, it would be a waste to throw the work away. Your bank, your customers and raters such as EcoVadis ask for the same evidence. And your board can steer better with it.

If you are an SME

For SMEs below the line there is no duty. The questions do come, though. A large customer sends a sustainability questionnaire, or the bank asks about your CO2 emissions for a loan. A tender sometimes asks for the CO2 Performance Ladder.

For this there is the Voluntary SME Standard (VSME), a voluntary set of questions for smaller companies. The Omnibus also limits what a reporting customer may ask of suppliers with up to 1,000 employeesSource: Linklaters, Sustainable Futures, Checked. What such a customer may ask goes no further than a voluntary standard based on the VSME. The exact rules are still to come. The upside is that you can reuse one set of answers.

How we go about it

First we check whether your company is in scope, looking at employees and turnover together. Then we list who already asks you questions: customers, the bank, investors. From that we choose one basic set of figures you use for all of them. For each figure we record where it comes from, so you can repeat it next year.

If your company is out of scope, we say so. We don’t make it more urgent than it is. The value is in an assessment you also use for your bank, your customers and your own choices.

Do you advise clients on this, as an accountant, lawyer or adviser? Then you get the same questions, and you can send us a client question too.

Would you like us to take a look? That usually starts with one question you send us.