Post-Omnibus CSRD: What the New Thresholds Mean for Your Reporting.

Why this matters.

CSRD was designed to bring sustainability reporting to the same level of rigour as financial reporting. The Omnibus I package, proposed by the European Commission in February 2025, sets out to reduce the reporting burden on smaller undertakings and to delay obligations for companies that had not yet started reporting.

For executives, the practical effect is twofold. First, fewer companies will be in direct scope than the original CSRD trajectory implied. Second, the simplification does not remove the underlying market pressure: large customers, lenders and procurement bodies will continue to ask for sustainability data from companies that fall out of direct scope.

Who is affected.

The Commission's proposal narrows the in-scope population by raising the size thresholds. Companies should monitor the final adopted text closely, as the precise thresholds and effective dates have moved during the legislative process.

Three groups should pay particular attention:

• Large undertakings that previously expected to report from FY2025 or FY2026 and may now have additional time, but still face customer-driven data requests.
• Listed SMEs, which were originally expected to report on a proportionate standard and whose obligations have been adjusted.
• Non-EU parents of EU subsidiaries, where the third-country reporting regime is being recalibrated alongside Omnibus changes.

What data and evidence companies should prepare.

Even with reduced direct scope, the European Sustainability Reporting Standards (ESRS) remain the reference point that customers and investors use when asking for data. Reporting teams should focus on the disclosures that travel through the value chain regardless of whether the company itself is required to publish a CSRD report:

• A double materiality assessment that documents which topics matter to the business and to its stakeholders.
• Greenhouse gas inventory covering Scope 1, 2 and the material parts of Scope 3, with a clear methodology and source data.
• Workforce and value-chain workforce data points used in ESRS S1 and S2.
• Governance evidence — policies, targets, responsibilities and the controls that support them.

How Regweaver helps.

Regweaver maps regulatory obligations to operational controls and evidence. For CSRD, this means translating the relevant ESRS data points into a structured set of controls that the company can evidence consistently — regardless of whether it reports directly or responds to customer questionnaires. The platform helps teams maintain the audit trail that auditors and large customers expect, and surfaces gaps before they become escalations.

Regweaver does not produce the report for you and does not replace your auditor. It gives compliance, sustainability and procurement teams a shared operational view of what is required, who owns it and what evidence exists today.