Omnibus I is no longer a proposal. It is law.
Today, 19 March 2026, Directive (EU) 2026/470, the Omnibus I package, enters into force. After months of proposals, negotiations, leaks, and shifting dates, this is no longer a draft. It is binding legislation. And the question we keep hearing from clients, prospects, and peers across the sector is always the same: what do I do now?
The answer depends on which group you belong to. So let us get straight to the point.
The numbers you need to know
The revised CSRD applies to companies that meet both criteria simultaneously:
- More than 1,000 employees on average during the financial year
- More than €450 million in net turnover
This is a radical shift from the original text. The practical result: of the roughly 50,000 companies that were expected to report under the original CSRD, only about 5,000 remain in scope. 90% have been excluded from mandatory reporting.
The ESRS, the reporting standards, are also simplified. Mandatory data points drop from 1,073 to 320. A 70% reduction.
Which group are you in?
Group 1: You exceed both thresholds (>1,000 employees and >€450M)
The CSRD applies to you. The key date is the financial year starting 1 January 2027, meaning you start collecting data this year to report the following year.
What you need to do now:
- Review your data systems to align with the simplified ESRS (the Delegated Act with the final version is expected by September 2026)
- Do not freeze what you have already built. Double materiality remains mandatory, although with a lighter process
- Prepare for limited assurance (assurance standards will be published before July 2027)
The key point here is that simplification is not an excuse to start from scratch in 2027. Companies that use this year to build their processes will be in far better shape than those who wait.
Group 2: You were in Wave 1 (reported in 2025) but now fall below the thresholds
This is the most sensitive situation. If your company already started reporting under the CSRD but has fewer than 1,000 employees or less than €450M in turnover, you can technically opt for a transitional exemption for 2025 and 2026.
However, this depends on how each Member State transposes the directive. Spain, for example, has not yet completed transposition (deadline: 19 March 2027). Until then, Ley 11/2018 remains in force.
Do not assume the exemption applies automatically. Consult your legal advisor before halting any reporting process.
Group 3: You were in Wave 2 or Wave 3 (set to begin in 2026 or 2027)
The wave system disappears. All companies that now exceed the thresholds share the same timeline: financial year 2027, reporting in 2028.
If you were already preparing to report sooner, your work has not been wasted. You simply have more time and fewer data points to collect.
Group 4: You are a supplier to a reporting company
There is an important change here that many are misreading: companies with fewer than 1,000 employees now have legal protection. They can legally refuse to provide information beyond the VSME standard (the voluntary SME standard that the Commission must publish before 19 July 2026).
This does not mean you should ignore data requests from your clients. It means there is a clear limit on what is reasonable to respond to. Know that limit.
What has NOT changed, and why it matters
The regulation has been simplified. Market pressure has not.
Investors continue to request climate data for access to green financing. Large clients reporting under the CSRD will keep requesting data from their value chain, now with the VSME as a reference, but they will keep requesting it. Public procurement increasingly incorporates ESG criteria.
The window opened by Omnibus I is an opportunity to build more efficient reporting processes, not to abandon what is already underway. Companies that use these months to solidify their systems will arrive at 2027 with a real competitive advantage.
The timeline you should save
| Milestone | Date |
|---|---|
| Omnibus I enters into force | 19 March 2026 (today) |
| VSME published (voluntary SME standard) | Before 19 July 2026 |
| Simplified ESRS, final Delegated Act | Before 18 September 2026 |
| National transposition deadline (Spain) | 19 March 2027 |
| First mandatory financial year under revised CSRD | Financial year 2027 |
| Limited assurance standards | Before 1 July 2027 |
Next steps
If you are unsure which group you belong to or what steps to take right now, that is a good sign to do a quick review of your situation. At Dcycle, we have been helping companies navigate exactly this moment for months. Our automated data collection tools adapt to the simplified ESRS, and our platform is designed to make compliance efficient regardless of whether you are in Group 1 or preparing as a value chain supplier.
Explore our CSRD resource hub for detailed guides, or request a demo to see how Dcycle can help you stay ahead.