Omnibus I changed the rules. For logistics, the pressure shifted. It didn’t disappear.
On 18 March 2026, Directive (EU) 2026/470 entered into force. The new CSRD thresholds — more than 1,000 employees AND more than €450 million net turnover — removed approximately 90% of previously obligated companies from scope.
For the logistics sector, this creates a paradox. Most logistics companies, including large fleet operators and 3PLs, fall below the new thresholds. But the companies they serve — manufacturers, retailers, consumer goods groups — are overwhelmingly still in scope. And those companies need Scope 3 transport data from their logistics providers to complete their own reports.
This article updates our CSRD guide for the logistics sector, published in March 2026 before Omnibus I became law. That version referenced timelines and dates that have since been confirmed or corrected.
For the full regulatory context, see CSRD Omnibus I approved: what changes for companies.
What changed for logistics companies
New scope thresholds
| Criteria | Before Omnibus I | After Omnibus I |
|---|---|---|
| Employees | More than 250 | More than 1,000 |
| Net turnover | More than €50M | More than €450M |
| Condition | Two of three criteria | Both must be met |
| Estimated companies in scope | ~50,000 | ~5,000 |
Most mid-market logistics companies — including regional carriers, freight forwarders, and logistics platforms — now fall outside mandatory CSRD reporting.
Updated timeline
| Wave | Who in logistics | Reports on FY | Report published |
|---|---|---|---|
| Wave 1 | Large listed logistics groups (already under NFRD) | FY2024 | 2025 (done) |
| Wave 2 | Logistics companies more than 1,000 employees AND more than €450M | FY2027 | 2028 |
| Wave 3 | Listed SMEs in logistics | FY2028 | 2029 |
Correction from our previous guide: Omnibus I was published on 26 February 2026 and entered into force on 18 March 2026. Our March 2026 logistics article referenced a December 2026 timeline for the reform. That date was incorrect.
Sectoral ESRS: dropped
The Omnibus I package confirmed what had been anticipated: sector-specific ESRS have been dropped entirely. There will be no dedicated logistics or transport standard. All in-scope companies report under the simplified cross-sector ESRS.
This does not mean logistics-specific topics disappear. The double materiality assessment still guides what you report. For most logistics companies, the most material topics remain: GHG emissions (particularly fleet and subcontracted transport), energy consumption, workforce conditions, and resource use.
Why out-of-scope logistics companies still need to report
The CSRD exemption does not exempt you from your customers’ CSRD obligations.
If your clients are in scope for CSRD, they are required to report on Scope 3 emissions. Transport and distribution — both upstream and downstream — are among the most significant Scope 3 categories for manufacturing, retail, and FMCG companies.
That means:
- Supplier questionnaires will increase, not decrease. Your clients’ reporting teams will need granular emissions data by route, mode, and shipment. “We’re not in scope” is not an acceptable response.
- VSME becomes your baseline. The Voluntary Standard for SMEs provides a structured framework to respond to supply chain data requests without full ESRS complexity.
- Data quality becomes a differentiator. Logistics companies that can provide automated, verified emissions data per shipment will win contracts. Those that send spreadsheets will lose them.
Spain: RD 214/2025 hits logistics directly
Spanish logistics companies covered by Ley 11/2018 (more than 250 employees with assets above €20M or turnover above €40M) must now:
- Calculate organisational carbon footprint for FY2025
- Publish a five-year GHG reduction plan with measurable targets
- Make both publicly available in 2026
This applies regardless of CSRD scope. The trigger is Spanish law, not EU directive.
For logistics companies, this means fleet emissions data, subcontractor emissions allocation, and modal split analysis are no longer optional — they are legally required inputs.
What logistics companies should do now
If you are still in scope (more than 1,000 employees AND more than €450M):
- Your first CSRD report covers FY2027, published in 2028
- Use the time to implement simplified ESRS when the Delegated Act is adopted (expected Q2–Q3 2026)
- Automate data collection from TMS, WMS, and fleet management systems now
If you are out of scope:
- Adopt VSME as your reporting baseline
- Comply with RD 214/2025 if you are in Spain and meet the criteria
- Build automated emissions data per shipment — your customers will demand it
- Consider voluntary ESRS reporting from FY2026 to demonstrate leadership
For all logistics companies: Stop treating reporting as a compliance exercise. The data you collect for CSRD/VSME is the same data that drives fuel cost optimization, route efficiency, and modal shift decisions. The companies that collect it systematically will have a lasting advantage over those that scramble to respond to customer requests.
For the broader picture on who reports when across all sectors, see the updated CSRD reporting timeline after Omnibus I.
See how Dcycle connects fleet data, supplier emissions, and multi-framework reporting →
Previous version: This article updates our CSRD guide for the logistics sector, published March 2026 before Omnibus I entered into force. That version is preserved for reference.
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