Omnibus I 2026: What Changed in CSRD for SMEs

Omnibus I is the single largest change to EU sustainability reporting since CSRD was adopted. For SMEs, the three most important consequences of the reform are: a narrowed scope of application, the codification of the value chain cap rule into the directive, and the gradual formalisation of VSME as a delegated act serving as the SME standard. This article explains exactly what changed and what SMEs should do in 2026.

The Situation in 2026: Omnibus I in Force, ESRS 2.0 in Preparation

The regulatory timeline currently looks as follows.

December 2025: EFRAG submitted its technical advice on simplified ESRS standards to the Commission. Draft versions had been published on 31 July 2025 and supplemented on 3 December 2025.

18 March 2026: Omnibus I Directive (EU) 2026/470 entered into force. The directive was published in the EU Official Journal on 26 February 2026. Member States have until 19 March 2027 to transpose the changes into national law. The new requirements apply to financial years beginning on 1 January 2027.

6 May 2026: The Commission opened a consultation on simplified ESRS standards (“ESRS 2.0”). The consultation closed on 3 June 2026.

Summer 2026: The final delegated act on ESRS 2.0 is expected.

Financial year 2027: First CSRD reports under the post-Omnibus I scope. “Wave 1” companies that fall outside the scope are exempt from reporting for both the 2025 and 2026 financial years.

The timeline matters because it determines when your customers will begin requesting data from you. In practice, pressure will build in the second half of 2026 as CSRD-obligated companies prepare their first reports for financial year 2027.

Three Key Changes for SMEs

Omnibus I contains dozens of individual amendments, but from an SME perspective three are decisive.

1. Raising the CSRD reporting threshold. The scope was significantly narrowed: now applying only to companies with more than 1,000 employees and a turnover above €450 million. The original directive would have obligated approximately 800–1,000 companies in Finland; after the reform, that number is considerably smaller. Most mid-sized companies that had been preparing for CSRD reporting are now outside the scope.

2. Codification of the value chain cap rule. A CSRD-obligated company may not request more sustainability data from a supplier with fewer than 1,000 employees than is defined in the VSME standard. The rule is written into the directive text, not merely into guidance, meaning it can be invoked directly in a customer relationship.

3. VSME transitioning to a delegated act. EFRAG submitted the VSME standard to the Commission in December 2024, and the European Commission issued an official recommendation on the matter in July 2025. As part of the Omnibus I package, VSME is being finalised as a delegated act, giving it official status as the content of the value chain cap. The content may still be slightly refined before the final act, but the framework is already widely in use.

Together, these three changes give SMEs a dual layer of protection. On one hand, a larger share of mid-sized and even large companies have been released from the CSRD obligation. On the other hand, those SMEs that continue to supply large CSRD-obligated companies can invoke a clear statutory cap on what a customer may request.

The Value Chain Cap in Practice: What Can Be Requested from a Supplier with Fewer Than 1,000 Employees

The value chain cap is the most important concrete right for SMEs in 2026.

The rule works as follows. A CSRD-obligated company (Customer A) sends you (SME supplier B) a sustainability data request. The request may contain dozens or hundreds of items. You have a statutory right to limit your response to what the VSME standard defines as data points.

Practical examples of what the cap covers and what it does not:

Covered: Scope 1 and Scope 2 emissions, energy consumption, basic workforce data, waste, water, basic governance information (Basic module). The Comprehensive module additionally covers climate risks, transition plan, human rights, and diversity.
Not covered: forms in the customer’s own reporting system format, product-level carbon footprints based on primary data without a separate agreement, certifications (e.g. ISO 14001) that your company does not hold.

If a customer requests information that clearly exceeds the VSME standard, you can invoke Omnibus I’s value chain cap rule and offer a response at VSME level only. A customer may request more on a voluntary basis or agree separately (for example by compensating for additional analysis), but you are under no obligation to provide more.

This is a practical change worth remembering. Previously, large customers could send dozens of different ESG questionnaires, each asking slightly different things. The cap gives SMEs the right to produce a single report and use it in response to multiple requests.

ESRS 2.0: A Simplified Set of Standards from 2027 Reporting Onwards

ESRS 2.0 is the informal name for the simplified ESRS standards that the Commission is preparing. The final delegated act is expected in summer 2026, and the standards will apply from financial year 2027.

The most important changes compared to the original ESRS standard set:

The number of data points will decrease significantly. The original ESRS set contained over 1,000 data points; ESRS 2.0 has reduced this considerably.
The “if applicable” principle expands. A company may choose not to report on sections that are not material to its business.
Materiality assessment plays a greater role. ESRS 2.0 relies more heavily on double materiality, which reduces the number of mandatory sections.
Implementation guidance becomes clearer. The standard’s terminology is intended to be more straightforward to interpret.

For SMEs, the significance of ESRS 2.0 is indirect. As reporting requirements lighten for CSRD-obligated customers, the questionnaires those customers send to their suppliers may also shorten. This is a positive direction, but in practice the relief will only become visible in the 2027–2028 reporting cycles.

A note on terminology: “Omnibus II” is sometimes mentioned in connection with CSRD. This is incorrect. Omnibus II is the InvestEU investment package (a €2.9 billion guarantee, entered into force 24 December 2025) and is unrelated to sustainability reporting. The correct term for the next phase is “ESRS 2.0 consultation” or “simplified ESRS.”

What SMEs Should Do Now in 2026

NGS recommends three concrete steps during the second half of 2026.

1. Identify your major CSRD-obligated customers. Review your 10–20 largest customers and assess whether they exceed the 1,000-employee and €450 million turnover thresholds. This will tell you where data requests will start coming from during 2026–2027. If your largest customer is clearly CSRD-obligated, it is worth being VSME-ready before the 2027 reporting cycle.

2. Build basic VSME readiness. This means completing Scope 1 and Scope 2 emissions calculations and establishing guidance for Basic-level data collection. Most SMEs will not need the Comprehensive level immediately, but the Basic level is in practice essential before customer requests start arriving. More information in the VSME Basic vs Comprehensive article.

3. Monitor the finalisation of ESRS 2.0. The Commission’s final delegated act is expected in summer 2026. The standard set may bring minor changes to VSME compatibility. In practice, a VSME report already completed will not become obsolete. New versions update the structure, they do not nullify previous work.

Our promise: you do not need to build a sustainability organisation. An NGS VSME project typically takes 4–8 weeks and handles data collection, calculation, and reporting on your behalf.

Frequently Asked Questions

What is the Omnibus package?

In EU legislation, “Omnibus” refers to a package that amends multiple existing directives in a single reform. Omnibus I (2026) focused on simplifying sustainability reporting. Omnibus II is a separate InvestEU investment package unrelated to sustainability.

When did Omnibus I enter into force?

Directive (EU) 2026/470 was published in the EU Official Journal on 26 February 2026 and entered into force on 18 March 2026. Member States must transpose the changes into national law by 19 March 2027. The new requirements apply to financial years beginning on 1 January 2027.

Does CSRD still apply to SMEs after Omnibus I?

Not directly. CSRD applies to companies with more than 1,000 employees and a turnover above €450 million. SMEs fall outside the scope. Indirectly, CSRD affects the SME sector through the value chain, as large customers request sustainability data from their suppliers.

What is ESRS 2.0?

ESRS 2.0 is the informal name for the simplified ESRS standards being prepared by EFRAG. The Commission consultation closed on 3 June 2026, and the final delegated act is expected in summer 2026. The standards will apply from financial year 2027.

Are further updates coming for SMEs?

In the short term, the major changes have already arrived. ESRS 2.0 will bring the standards to their final form in summer 2026. In the longer term, it is possible that the VSME standard will be updated, but no such changes have yet been officially scheduled.

Does a VSME report need to be redone because of ESRS 2.0 changes?

No. A VSME report already completed remains valid even if the standard set is updated. ESRS 2.0 changes primarily concern reporting by CSRD-obligated companies, not the VSME structure as such. In practice, updates will appear as minor changes to data points in the next reporting cycle’s VSME report.

Unsure whether Omnibus applies to your company?

In 30 minutes we can go through whether you are CSRD-obligated under the 2026 rules, how the value chain cap protects you, and what concrete steps need to be taken.

Book a 30-minute scoping call · Explore the VSME service