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Regime 02 · Corporate Sustainability Reporting Directive

The Omnibus narrowed CSRD. It did not narrow yours.

The 2025 simplification raised the thresholds and delayed later waves — but a large energy, oil and gas or mining group sits comfortably above the new bar of 1,000 employees and €450m turnover. And even where a company falls out of mandatory scope, banks, investors and EU customers continue to demand ESRS-comparable data through the value chain. The reporting obligation is sharper, not softer, for the groups we serve.

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>1,000Employees — revised threshold
>€450mNet turnover — revised threshold
FY2025–26Wave 1 still reporting
FY2027Wave 2 first report (in 2028)
~1,100ESRS datapoints to govern

Where the directive stands now

What the Omnibus actually changed.

The Omnibus I package entered into force on 18 March 2026, with member states given twelve months to transpose. It raised scope thresholds, removed listed SMEs from mandatory scope and pushed Wave 2 reporting back two years. It did not abolish CSRD, and it did not relieve in-scope Wave 1 companies of their continuing obligations. The simplified ESRS are expected mid-2026.

Apr 2025Stop-the-clockWave 2 and 3 reporting deferred by two years.
18 Mar 2026 · nowOmnibus in forceRevised thresholds; 12-month transposition window opens.
FY2025–26Wave 1 reportsIn-scope first-wave groups continue reporting in 2026 and 2027.
Mid 2026Revised ESRSSimplified standards expected to be adopted.
FY2027Wave 2 beginsLarge second-wave groups first report in 2028.
FY2028Non-EU groupsIn-scope non-EU parents report in 2029.

Who this concerns

Large emitters and their value chains.

Energy, oil & gas, mining

Capital-intensive groups well above the revised thresholds, with material climate, pollution and biodiversity datapoints.

Non-EU parents

Groups with significant EU turnover that fall into scope from FY2028, reporting in 2029.

Value-chain suppliers

Companies out of mandatory scope but facing ESRS-aligned data requests from customers, banks and lenders.

Boards & audit committees

Directors accountable for a double-materiality assessment that withstands limited assurance.

The reassessment trap. The single most common 2026 error is assuming the Omnibus means "nothing to do". For in-scope groups it does not — and the double-materiality assessment, datapoint mapping and assurance-evidence trail take far longer to build than the deadline suggests.

CSRD instruments

From datapoint control to a board-ready assessment.

Authored for energy and extractives — not a generic ESG template. Instant download, transparent sterling pricing.

Forthcoming · Excel

ESRS Datapoint Tracker

Reporting teams mapping the ~1,100 ESRS datapoints to owners and evidence.

  • Datapoint mapping workbook
  • Gap-analysis & ownership register
  • Assurance-evidence index
  • Reporting-timeline tracker
£397Excel + guide
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Sector toolkit

CSRD Energy & Extractives Readiness Toolkit

Energy, oil & gas and mining groups drawn into the ESRS reporting net.

  • Double-materiality assessment structure
  • ESRS datapoint mapping for extractives
  • Assurance-evidence index
  • Board readiness narrative
£497Sector toolkit
Buy the toolkit

A double-materiality starter guide and a director-level CSRD readiness board pack are also in development for this regime.

From toolkit to mandate

Unsure whether you are still in scope?

A CSRD scope call confirms your reporting obligation under the revised thresholds, identifies your likely material topics and sequences the work so the assessment is defensible under assurance.

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