CSRD Omnibus Package
The Omnibus package, published February 2025, is the most significant change to CSRD since it passed. It narrowed scope from 50,000 to roughly 5,000–10,000 companies, delayed Wave 2 and 3 deadlines by two years, and reduced ESRS datapoints by 61%. Here is exactly what changed.
The Omnibus package, published February 2025, is the most significant change to CSRD since it passed. The original CSRD applied to companies meeting at least two of three criteria: 250+ employees, €40M+ turnover, €20M+ assets.
The scope change — who is now excluded
The original CSRD applied to companies meeting at least two of three criteria: 250+ employees, €40M+ turnover, €20M+ assets. This caught approximately 50,000 companies.
The Omnibus package changed this to 1,000+ employees AND €450M+ turnover — both must be met simultaneously. This reduces mandatory scope to approximately 5,000–10,000 companies.
Companies with 250–999 employees, or with €40M–€449M turnover, are no longer in mandatory CSRD scope under Omnibus. However, supply chain pressure from large CSRD reporters means these companies will still need to provide ESG data to their customers.
The deadline changes
Wave 1 (large PIEs, already reporting under NFRD): No change. These companies file their FY2024 report in 2025 and continue unchanged.
Wave 2 (original scope of large companies): Delayed from FY2025 to FY2027. First report now published in 2028.
Wave 3 (listed SMEs): Removed from mandatory scope entirely under Omnibus. Can opt in voluntarily.
Wave 4 (non-EU companies): Delayed from FY2026 to FY2028. First report published in 2029. Turnover threshold raised from €150M to €450M.
The Amended ESRS — 61% fewer datapoints
EFRAG published the Amended ESRS in December 2025, cutting mandatory datapoints by approximately 61%. The reduction focuses on eliminating duplicative, unclear, or disproportionately burdensome datapoints.
The core structure of the 12 ESRS standards remains unchanged. The amendments affect which specific datapoints within each standard are mandatory vs voluntary.
Wave 1 companies continue reporting under original ESRS (with some reliefs). Wave 2 companies will report under Amended ESRS from FY2027.
Frequently asked questions
I was in CSRD scope before Omnibus. Am I still required to report?
Only if you have 1,000+ employees AND €450M+ net turnover. If you are below either threshold, you are no longer in mandatory scope. Wave 1 companies (already reporting under NFRD) are not affected by the scope reduction.
Has the Omnibus been formally adopted?
The Stop-the-Clock regulation was adopted in April 2025, delaying Wave 2 and 3 deadlines. The full Omnibus scope and threshold changes are subject to final trilogue negotiations. Monitor EFRAG and European Commission announcements.
Should companies outside the new scope still prepare for CSRD?
Yes — for two reasons. First, member states can set stricter national thresholds. Second, your large customers will request ESRD-equivalent data for their own Scope 3 and supply chain disclosures.