The CSRD timeline has been rewritten. Here is what applies now.
On 18 March 2026, Directive (EU) 2026/470 — the Omnibus I package — entered into force. It is the most significant change to EU sustainability reporting since the CSRD was adopted in 2022.
If you planned your reporting schedule based on the original CSRD waves, that plan is likely outdated. The thresholds changed. The waves shifted. The number of companies in scope dropped from an estimated 50,000 to roughly 5,000. And the ESRS — the reporting standards themselves — are being simplified, with a Delegated Act expected by Q3 2026.
This article replaces our previous CSRD calendar 2026–2030 published in March 2026, which was written before Omnibus I became law. Everything below reflects the rules as they stand today.
For a full breakdown of what Omnibus I changed at the political level, see CSRD Omnibus I approved: what changes for companies.
New thresholds: who is in scope for CSRD after Omnibus I
The Omnibus I Directive replaced the original CSRD scope criteria with a dual threshold:
- More than 1,000 employees, AND
- More than €450 million net turnover
Both conditions must be met. This replaces the previous framework that captured companies with 250+ employees and €50 million+ turnover.
The result: approximately 90% of companies previously expected to report under CSRD are now out of scope.
Third-country companies (non-EU parent) remain subject to CSRD if they generate more than €150 million net turnover in the EU and have at least one subsidiary or branch meeting the relevant thresholds. However, the Delegated Act for non-EU ESRS is not expected before October 2027.
Updated wave calendar: who reports when
Wave 1: already reporting (unchanged)
- Who: Companies already subject to NFRD (public-interest entities with more than 500 employees)
- First report: Published in 2025, covering financial year 2024
- Status post-Omnibus: Still reporting. Those that now fall below the new thresholds (more than 1,000 employees / more than €450M) get a transition exemption for FY2025 and FY2026. Member States may choose to exempt them during this period. From FY2027, the new scope applies.
- Quick-fix relief: The July 2025 Delegated Act extended phase-in provisions, allowing Wave 1 companies to omit ESRS E4, S2, S3, and S4 for FY2025–2026 even if those topics are material.
Wave 2: postponed by two years
- Who: Large companies (more than 1,000 employees AND more than €450M) not already in Wave 1
- Original deadline: FY2025 (report in 2026)
- New deadline after stop-the-clock and Omnibus I: FY2027 (report in 2028)
- Standards: Simplified ESRS (Delegated Act expected mid-to-late 2026), applicable from FY2027. Voluntary early adoption possible for FY2026.
Wave 3: postponed by two years
- Who: Listed SMEs, small and non-complex credit institutions, captive insurance entities
- Original deadline: FY2026 (report in 2027)
- New deadline: FY2028 (report in 2029)
- Standards: Simplified ESRS or VSME-based standards
Wave 4: third-country companies (unchanged)
- Who: Non-EU companies with more than €150M EU turnover and qualifying subsidiaries/branches
- Original deadline: FY2028 (report in 2029)
- Standards: Non-EU ESRS. Delegated Act not expected before October 2027.
What changed with ESRS
The European Sustainability Reporting Standards are being simplified. EFRAG delivered its technical advice to the Commission in December 2025. Key changes:
- Mandatory datapoints reduced by approximately 61% (from 1,073 to roughly 320 in some estimates; others cite up to 70% reduction depending on methodology)
- Double materiality assessment gets more flexibility: companies can now use top-down or bottom-up approaches
- Topical opt-outs extended: Wave 1 companies can skip E4 (biodiversity), S2 (value chain workers), S3 (communities), S4 (consumers) for FY2025–2026
- Assurance: Limited assurance remains the standard. Full (reasonable) assurance is postponed.
The Commission plans to adopt the simplified ESRS Delegated Act before Q4 2026, for the new standards to apply from FY2027. Companies may be allowed to voluntarily apply them for FY2026.
CSDDD: what happened to due diligence
Omnibus I also significantly changed the Corporate Sustainability Due Diligence Directive:
- Threshold raised: From more than 1,000 employees to more than 5,000 employees AND more than €1,500 million turnover
- Transposition deadline: 26 July 2028
- Application: From 26 July 2029
- Practical impact: Most mid-market companies are now out of scope entirely.
Spain: the specific situation
Spain has not yet transposed the CSRD into national law. The transposition bill (Ley de Información Empresarial sobre Sostenibilidad, LEIS) has been in Parliament since November 2024 with no visible progress.
The European Commission has open infringement proceedings against Spain (along with Austria, Czech Republic, Germany, Luxembourg, Malta, Netherlands, and Portugal) for failing to meet the original transposition deadline of July 2024.
However, Spanish companies are not in a regulatory vacuum:
- Royal Decree 214/2025 makes organisational carbon footprint calculation mandatory for companies under Ley 11/2018 (more than 250 employees with either assets above €20M or turnover above €40M). First publication is due in 2026, using FY2025 data. This includes a mandatory five-year GHG reduction plan.
- Omnibus I requires Member State transposition by 19 March 2027.
- CSDDD transposition deadline is July 2026, and Spain has not published a draft bill.
For Spanish companies, the practical trigger is clear: even if the CSRD is not yet transposed, RD 214/2025 already creates binding obligations. Investors, lenders, and supply chain partners are not waiting for legislation to ask for data.
What to do if you are no longer in scope
The ~90% of companies that Omnibus I removed from CSRD scope face a strategic question, not a compliance one. Regulation may have stepped back, but stakeholder expectations have not:
- Investors and banks still require ESG data for lending decisions, fund mandates, and EU Taxonomy alignment.
- Supply chain partners subject to CSRD or CSDDD will continue requesting Scope 3 data from their suppliers — regardless of whether those suppliers are themselves in scope.
- VSME (Voluntary Standard for SMEs) is emerging as the de facto reporting baseline for companies outside CSRD scope. It provides a lean framework that satisfies most supply chain requests without full ESRS complexity.
- Voluntary reporting under simplified ESRS may be available from FY2026, giving companies a head start before potential future scope expansions.
The companies that use this simplification as a reason to stop collecting data entirely will find themselves unprepared when requirements inevitably tighten — or when their next financing round demands information they no longer have.
As we wrote in our Omnibus I analysis: the question is not whether to adapt, but how strategically you do it.
Timeline summary table
| Wave | Who | First FY | First report | Standards |
|---|---|---|---|---|
| Wave 1 | NFRD companies (more than 500 employees, public interest) | FY2024 | 2025 | Current ESRS (simplified from FY2027) |
| Wave 1 (below new thresholds) | Wave 1 companies with fewer than 1,000 employees or below €450M | FY2025–2026 exempt (Member State option) | — | — |
| Wave 2 | Large companies (more than 1,000 emp AND more than €450M) | FY2027 | 2028 | Simplified ESRS |
| Wave 3 | Listed SMEs | FY2028 | 2029 | VSME-based standards |
| Wave 4 | Non-EU companies (more than €150M EU turnover) | FY2028 | 2029 | Non-EU ESRS (TBD) |
| CSDDD | More than 5,000 employees AND more than €1,500M | Transposition: July 2028 | Application: July 2029 | — |
What this means for your reporting tools
If your company is in the ~5,000 still in scope, the demands on your reporting system are unchanged. Simplified ESRS does not mean simpler data collection. You still need automated data pipelines, multi-framework mapping, and audit-ready traceability.
If your company is newly out of scope, the smart move is not to dismantle your reporting infrastructure. It is to shift it toward VSME compliance, voluntary disclosure, and supply-chain readiness. The same platform that handles CSRD handles VSME, carbon footprint under RD 214/2025, and CDP — with one data entry feeding every framework.
For logistics companies specifically, the Omnibus I changes have a distinct impact. See our updated CSRD for logistics after Omnibus I for the sector-specific picture.
See how Dcycle automates sustainability reporting →
Previous version: This article updates our CSRD calendar 2026–2030, published March 2026 before Omnibus I entered into force. That version is preserved for reference.
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