EU carbon rules / Regulations / Omnibus I Amendment
In force Directive Sustainability reporting & due diligence
Omnibus I Amendment
Amends 2022/2464 (CSRD) and 2024/1760 (CSDDD); narrows scope and thresholds (transposition deadline 2027-03-19)
- Reference
- Directive (EU) 2026/470
- Key date
- 2026-03-18 entry into force
- Applies to
- Companies covered and to be covered by CSRD/CSDDD
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Who the regulation applies to
This regulation applies to:
- CSRD (Directive 2013/34/EU): mandatory sustainability reporting is limited to undertakings with net turnover exceeding EUR 450 000 000 at the balance sheet date and more than 1 000 average employees during the financial year
- CSRD: the consolidated reporting threshold is likewise net turnover exceeding EUR 450 000 000 and more than 1 000 average employees; listed SMEs (including small non-complex credit institutions, etc.) are removed from the mandatory scope
- CSRD: third-country undertakings' EU subsidiaries or branches with net turnover exceeding EUR 200 000 000 and whose third-country parent has net turnover in the EU exceeding EUR 450 000 000 must publish group sustainability information (Article 40a)
- CSDDD (Directive (EU) 2024/1760): limited to companies with more than 5 000 average employees during the financial year and global net turnover exceeding EUR 1 500 000 000 in the preceding financial year
- CSDDD: franchise/licence agreements with royalties exceeding EUR 75 000 000 and global net turnover exceeding EUR 275 000 000; third-country companies with net turnover in the EU exceeding EUR 1 500 000 000
- (Protection) Undertakings in the value chain with no more than 1 000 average employees in the financial year preceding the balance sheet date (‘protected undertakings’): may refuse information requests beyond the voluntary standard (VS)
- (Not applicable) The European Financial Stability Facility (EFSF); financial products listed in Article 2(12), points (b) and (f), of Regulation (EU) 2019/2088
- (Condition) Member States may exempt undertakings below the new thresholds from reporting obligations for financial years 2025–2026
Directive (EU) 2026/470 is an amending directive: it raises the CSRD mandatory sustainability reporting threshold to net turnover exceeding EUR 450 000 000 and more than 1 000 average employees, and raises the CSDDD thresholds to more than 5 000 average employees and global net turnover exceeding EUR 1 500 000 000 (for franchises, royalties exceeding EUR 75 000 000 and net turnover exceeding EUR 275 000 000). Transposition deadline: 19 March 2027.
The following provisions define its scope:
Article 2(1)(a) — replaced Article 1(3) of Directive 2013/34/EU
The coordination measures prescribed by Articles 19a, 29a, 29d, 30 and 33, point (aa) of the second subparagraph of Article 34(1), Article 34(2) and (3), and Article 51 of this Directive shall also apply to the laws, regulations and administrative provisions of the Member States relating to the following undertakings regardless of their legal form, provided that those undertakings are undertakings which, on their balance sheet dates, exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year:
Article 2(4)(a) — replaced Article 19a(1) of Directive 2013/34/EU
Undertakings which, on their balance sheet dates, exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year shall include in their management report information necessary to understand the undertaking’s impacts on sustainability matters, and information necessary to understand how sustainability matters affect the undertaking’s development, performance and position.
Article 4(2)(a)(i) — replaced Article 2(1)(a) of Directive (EU) 2024/1760 (CSDDD)
the company had more than 5 000 employees on average and had a net worldwide turnover of more than EUR 1 500 000 000 in the last financial year for which annual financial statements have been or should have been adopted;
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What the regulation requires
| Duty | Trigger | Evidence | Timing |
Re-assess coverage against the new thresholds
The reporting threshold is raised to more than 1,000 employees and reporting content is simplified by around 60% of data points. | Companies close to the original CSRD thresholds | Assessment based on employee numbers and revenue | After 2026/470 enters into force |
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Key provisions
Article 1 — amended Article 19a(1) scope (CSRD)
‘The coordination measures prescribed by Articles 19a, 29a, 29d, 30 and 33, point (aa) of the second subparagraph of Article 34(1), Article 34(2) and (3), and Article 51 of this Directive shall also apply to the laws, regulations and administrative provisions of the Member States relating to the following undertakings regardless of their legal form, provided that those undertakings are, on their balance sheet dates, exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year:’
Article 4 — amended Directive (EU) 2024/1760 Article 2(1) (CSDDD scope)
the company had more than 5 000 employees on average and had a net worldwide turnover of more than EUR 1 500 000 000 in the last financial year for which annual financial statements have been or should have been adopted;
Article 4 — amended Article 10(2) (targeted requests to business partners)
companies may request information from business partners only where that information is necessary, and, in the case of business partners with fewer than 5 000 employees, only when the information cannot reasonably be obtained by other means;
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Industry dossiers covering this regulation