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The final text of the Omnibus I package amending the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) has now been published in the Official Journal of the European Union.
Publication in the Official Journal marks the completion of the EU legislative process for Omnibus I. The Directive will enter into force on 18 March 2026, 20 days after publication.
This follows approval of the corrigendum text (arising from the lawyer‑linguist review of all language versions) by the European Parliament on 26 January 2026 and by the Council earlier this week.
Key dates and expected milestones
We have set out below a summary timeline of the key procedural milestones arising from the Omnibus I package and related sustainability reporting developments.
| Item | Date / timing |
|---|---|
| Publication of directive amending CSRD and CSDDD (Directive (EU) 2026/470) in the Official Journal | 26 February 2026 |
| Entry into force of the directive amending CSRD and CSDDD | 18 March 2026 |
| Expected adoption of draft ESRS Delegated Act (simplifying ESRS) and start of scrutiny period | Q2 2026 |
| Expected publication of the revised ESRS Delegated Act in the EU Official Journal and entry into effect. | Q4 2026 (entry into effect on the day following its publication in the EU Official Journal) |
| Draft non‑EU sustainability reporting standards (NESRS) | Expected in 2027 |
| CSRD amendments – Member State transposition deadline | 19 March 2027 |
| CSDDD amendments – Member State transposition deadline | 26 July 2028 |
| Start of CSRD reporting obligations under Article 19a (individual EU undertaking) and 29a (EU parent undertaking of a consolidated group) | First reporting for FY2027 (reports published in 2028) |
| Start of CSRD reporting obligations under Article 40a (third-country parent regime) | First reporting for FY2028 (reports published in 2029) |
| Start of CSDDD due diligence and reporting obligations | From 26 July 2029, with reporting from 1 January 2030 |
For our analysis of the substantive amendments to the CSRD and CSDDD introduced by the CSRD and CSDDD Amendment Directive, please see our earlier publication.
Next steps
With publication in the Official Journal, the legislative process for Omnibus I has concluded. The focus now shifts to implementation and operationalisation. Key areas to monitor include:
- national transposition of the Omnibus I directive - national implementing legislation will determine the precise application of exemptions, transitional measures and enforcement mechanisms.
- the simplification of the ESRS, including the forthcoming Delegated Act to be adopted by the European Commission, which will determine the future reporting requirements for in‑scope undertakings;
- the forthcoming EU voluntary sustainability reporting standards, building on the VSME framework, which will be relevant both for companies outside of the mandatory scope and for value‑chain information requests; and
- the development of non‑EU sustainability reporting standards for the third‑country parent regime.
A significant policy rationale for Omnibus I and its related reduction in overall scope of the CSRD and CS3D, is a stated aim of reducing reporting burdens on corporates to support competitiveness. From a business perspective, this should not be read as implying that sustainability reporting is "optional" in practice. Many companies will still face:
- investor and lender disclosure expectations;
- customer supply‑chain requirements;
- internal governance demands; and
- reputational risk from perceived backsliding.
In other words, while companies may now fall outside of the mandatory reporting scope as a matter of law, the underlying sustainability‑related risks and impacts remain, and boards will continue to require relevant information to support effective oversight and risk management.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
