CSRD Omnibus 2026 — Directive (EU) 2026/470 recalibrating CSRD/CSDDD thresholds
Directive (EU) 2026/470, of 24 Feb 2026, reducing the subjective scope of the CSRD and the CSDDD to a DOUBLE AND CUMULATIVE threshold: more than 1,000 employees AND net turnover above EUR 450,000,000.
Context
The CSRD Omnibus 2026 is the legislative piece with which the Commission, the Parliament and the Council recalibrate downwards the universe of companies subject to the sustainability reporting regime introduced by the CSRD (Directive (EU) 2022/2464) and to the due diligence regime introduced by the CSDDD (Directive (EU) 2024/1760). The core change is the shift to a DOUBLE AND CUMULATIVE threshold: only companies exceeding both size criteria simultaneously remain bound.
Regulatory origin
Directive (EU) 2026/470 of the European Parliament and of the Council, of 24 February 2026, published in the Official Journal of the European Union (L Series) on 26 February 2026, canonical ELI `http://data.europa.eu/eli/dir/2026/470/oj`. Legal basis Arts. 50 and 114 TFEU. Signed in Brussels by R. METSOLA (Parliament) and C. KOMBOS (Council).
DOUBLE AND CUMULATIVE threshold (AND, not OR)
Employees: average number above 1,000 during the financial year.
Net turnover: above EUR 450,000,000.
Only when both criteria are met simultaneously does the company fall within the CSRD scope (Arts. 19a and 29a of Directive 2013/34/EU as amended).
The balance sheet total criterion disappears from the CSRD formula post-Omnibus (the Accounting Directive 2013/34/EU Art. 3 retains it for general accounting classification).
«It is necessary for the obligation to draw up and publish sustainability information at individual level to be limited to companies with a net turnover above EUR 450,000,000 and exceeding the average number of 1,000 employees during the financial year.»
Four instruments amended
Amends Directive 2006/43/EC (statutory audit): regime for the assurance of sustainability information, deadline for adopting limited assurance standards extended to 1 July 2027 (recital 4) and removal of the mandate to adopt reasonable assurance standards (recital 5).
Amends Directive 2013/34/EU (Accounting Directive): introduces the DOUBLE AND CUMULATIVE threshold in Arts. 19a, 29a and 40a, adjusts the XBRL tagging regime (recital 24) and reduces the scope of intangible resources disclosures (recital 11).
Amends Directive (EU) 2022/2464 (CSRD): adjusts the phased calendar of Art. 5(2), limiting point (a) to three financial years from 1 Jan 2024 and applying point (b) to financial years beginning on or after 1 Jan 2027 (recitals 31 and 33).
Amends Directive (EU) 2024/1760 (CSDDD): defers the application date to 26 Jul 2029 (Art. 22), caps pecuniary penalties at 3% of net worldwide turnover (Art. 27.4) and adjusts the civil liability regime (Art. 29).
Timeline
Communication A Simpler and Faster Europe
The Commission presents its implementation and simplification programme (recital 1).
European Parliament position
Approval at first reading.
Council decision · adoption
Signed by R. METSOLA and C. KOMBOS in Brussels.
OJEU publication
Official Journal L Series · 2026/470.
Entry into force
On the twentieth day following publication (Art. 6).
Transposition deadline Arts. 1-3
Member States adopt the national provisions (Art. 5.1).
First application of the new CSRD thresholds
Companies exceeding >1,000 employees AND >EUR 450,000,000 (recitals 31 and 33).
Transposition deadline Art. 4 (CSDDD)
Member States adopt the national provisions on due diligence (Art. 5.1).
Application of the new CSDDD rules
Effective application of the amendments to Directive (EU) 2024/1760.
Applied case
A European textile brand with net turnover of EUR 80,000,000 and 320 people on its payroll assesses its CSRD exposure before and after the 2026 Omnibus.
Pre-Omnibus: it was a candidate to enter the wave of large companies under the original CSRD, with first application in the 2025 financial year (Art. 5(2)(b) of Directive (EU) 2022/2464 in its earlier wording).
Post-Omnibus: it falls OUTSIDE the mandatory CSRD scope because it does not simultaneously exceed >1,000 employees AND >EUR 450,000,000 (recital 7 + Art. 19a amended of Directive 2013/34/EU).
Even so, large B2B customers that remain bound may continue to request data via the value chain information route (recital 21 limits that request to what is disclosable under the voluntary VSME standard).
Common mistakes
The 2026 Omnibus does NOT repeal the CSRD: it recalibrates it.
Directive (EU) 2026/470 amends Arts. 19a, 29a and 40a of Directive 2013/34/EU and Art. 5 of Directive (EU) 2022/2464, but retains the substantive sustainability reporting regime under the ESRS. What changes is the subjective scope (companies affected) and the calendar, not the architecture of the Sustainability Statement.
The threshold is DOUBLE AND CUMULATIVE (AND), not alternative (OR).
Recital 7 cites verbatim "with a net turnover above EUR 450,000,000 AND exceeding the average number of 1,000 employees during the financial year". Meeting only one does not trigger the CSRD obligation post-Omnibus. The difference from the previous regime of the Accounting Directive (which classified by exceeding two of three criteria) is structural.
Falling outside the CSRD scope post-Omnibus does NOT exempt from other EU obligations.
The Omnibus package only amends the CSRD, CSDDD, the Accounting Directive and statutory audit. It does not affect the ESPR (Reg. (EU) 2024/1781), the EUDR (Reg. (EU) 2023/1115), the Forced Labour Regulation (Reg. (EU) 2024/3015), the ECGT Directive (Dir. (EU) 2024/825), the Right to Repair Directive (Dir. (EU) 2024/1799), the Spanish textile EPR scheme (RD 1055/2022) nor equivalent EPR regimes. Whoever falls outside the CSRD remains subject to the applicable sectoral material obligations.
Excluded companies may still report voluntarily.
Recital 7 in fine, faithfully paraphrased: companies, groups and issuers below the specified thresholds remain free to report sustainability information voluntarily, a possibility facilitated by the voluntary standards introduced by the Directive. Recital 22 designates Recommendation (EU) 2025/1710 (VSME) as the basis until the Commission adopts, by delegated act, its own voluntary standard.
The Omnibus does NOT directly amend ESRS Set 1.
The review of the ESRS is conducted by EFRAG under a separate mandate and materialises via a Commission Delegated Regulation (references in recital 20 on the removal of the power to adopt sectoral standards). The package in force for companies that remain bound continues to be Delegated Regulation (EU) 2023/2772, amended by the corrigendum of 19 Apr 2024 and by Delegated Regulation (EU) 2025/1416 ("QuickFix").
Frequently asked questions
What is the CSRD Omnibus 2026?
Directive (EU) 2026/470 of the European Parliament and of the Council, of 24 February 2026, amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 (CSRD) and (EU) 2024/1760 (CSDDD), recalibrating the subjective scope of sustainability reporting and of due diligence.
What is the new CSRD threshold post-Omnibus?
A DOUBLE AND CUMULATIVE threshold (recital 7 + Arts. 19a and 29a amended): more than 1,000 employees on average during the financial year AND more than EUR 450,000,000 of net turnover. Both are required simultaneously: meeting only one does not trigger the obligation.
When does the Omnibus enter into force?
On the twentieth day following its publication in the OJEU L Series of 26 February 2026, i.e. 18 March 2026 (Art. 6). The transposition deadline for Arts. 1-3 is 19 March 2027 (Art. 5.1 first subparagraph) and for Art. 4 on the CSDDD 26 July 2028 (second subparagraph).
When do the new thresholds apply for the first time?
To financial years beginning on or after 1 January 2027 (recitals 31 and 33). For financial years between 1 January 2025 and 31 December 2026, Member States may exempt companies that cease to be bound, respecting the principle of legal certainty.
Who falls outside the mandatory CSRD with the Omnibus?
Any company that does not simultaneously exceed >1,000 employees AND >EUR 450,000,000 (recital 7). They may continue to report voluntarily under the VSME standard (Recommendation (EU) 2025/1710, reflected in recital 22) until the Commission adopts, by delegated act, its own voluntary standard based on the VSME developed by EFRAG.
Does the Omnibus touch ESRS Set 1?
Not directly. The Omnibus amends the subjective scope and the CSRD/CSDDD calendar but does not repeal Delegated Regulation (EU) 2023/2772 adopting ESRS Set 1. The technical review of the ESRS is conducted by EFRAG under a separate mandate.
What changes for companies subject to the CSDDD?
Art. 4 of the Omnibus amends Directive (EU) 2024/1760 by deferring the application date to 26 July 2029 (Art. 22), reducing the maximum cap on pecuniary penalties to 3% of net worldwide turnover (Art. 27.4) and adjusting the civil liability regime (Art. 29).
Fuentes oficiales
- European Parliament and Council · OJEU Series L, 26 Feb 202624 feb 2026Directive — legislation in force
- European Parliament and Council · OJEU L 322, 16 Dec 202214 dic 2022Base instrument amended
- European Parliament and Council · OJEU L, 5 Jul 202413 jun 2024Base instrument amended
- European Commission · OJEU L, 5 Aug 202530 jul 2025Recommendation cited in recital 22
