On February 26, 2026, the European Union released the Directive 2026/470 (Omnibus Amending Directive) facts have been created in the EU Official Journal. The new regulations bring some adjustments User groups for CSRD and CSDDD. Through significantly increased thresholds, a large portion of the middle class is exempted from direct reporting obligations. Additionally, the EU intends to strengthen legal certainty for companies and facilitate sustainability reporting. While this represents an enormous bureaucratic relief for many companies, the affected large market players, however, are feeling pressure from the „Trickle-down effect“ Next.
CSRD Reporting Obligation 2026: Who is currently affected?
The biggest change concerns the Corporate Sustainability Reporting Directive (CSRD). The EU has revised its original plans to include companies with 250 or more employees in order to reduce the administrative burden. As a result, the requirement no longer applies to approximately 90,000 of the companies originally targeted.
- New CSRD thresholds: In the future, only companies with more than 1,000 employees and an annual turnover of over 450 million euros.
- Deadline & Start: For the remaining companies, the obligation begins uniformly from Fiscal year 2027.
- LSME - Standard for SMEs RemainsFor listed small and medium-sized enterprises (SMEs) that are also subject to reporting requirements, LSME reporting (Listed Small and Medium-Sized Enterprises) will be introduced.
- Voluntary VSME reports still possibleTo counteract the trickle-down effect, non-capital market-oriented SMEs can continue to submit VSME („Voluntary Small and Medium-sized Enterprises“) reports.
Since the current draft of the CSRD implementation has not yet been ratified in Germany, the national legislative process is to be based on the ESRS-Starting updates. This will be used as a delegated act in 2nd Quarter 2026 expected. For companies currently subject to the NFRD, CSRD data collection will apply from 2026. For newly affected companies, it will apply from 2027 with a reporting obligation in 2028. The standards for the LSME and VSME sustainability reports should become significantly less complex and offer simplified disclosure requirements.
CSDDD Update: New Limits for the EU Supply Chain Law
Even with the Corporate Sustainability Due Diligence Directive (CSDDD) Are there significant changes? The EU has now replaced the previously planned gradual introduction with a uniform regulation. The most important CSDDD changes at a glance:
- Higher hurdles Only large companies with more than 5,000 employees and about 1.5 billion € revenue fall directly under the EU directive.
- Uniform start date The application start has been set for all affected companies to the July 26, 2029 postponed.
- Adaptation of the LkSG: The German federal government must now the existing Supply Chain Due Diligence Act adapt to these new EU standards, which could mean relief for many German companies.
Why those not directly affected must still act
1. The „Data Pass“: Those who don't deliver are out
Reporting large corporations (> 1,000 employees) must disclose their entire value chain. As suppliers, they are not legally obligated, but usually contractual obligated to provide data. Those who cannot provide a CO₂ balance or social proof risk being delisted as a supplier.
2. Standardization saves costs (ESRS pull effect)
Instead of responding to individual questionnaires from each customer, it is recommended to orient yourself by LSME- or VSME Standard (for unlisted SMEs). A one-time, standardized data preparation saves time and signals professionalism to clients.
3. Banks & Green Finance
The EU taxonomy obliges banks to assess the sustainability of their loan portfolios. Companies without ESG transparency will in the future face higher interest rates or more difficult loan approvals. Sustainability data is therefore a direct prerequisite for attractive financing conditions.
Comparison: Old Planning vs. New EU Directive 2026
| Criterion | Booth 2024 | Update 2026 |
| CSRD Focus | staggered from 250 employees / 40 million € revenue | From 1,000 MA / 450 million € revenue |
| CSDDD Focus | From 1,000 MA / 450 million € revenue | From 5,000 employees / €1.5 billion in revenue |
| Start Date CSDDD | Phased in starting 2027 | Uniform July 26, 2029 |
| Legal certainty | Drafts / Negotiations | Omnibus Directive 2026/470 |
| Reporting Standard | Full ESRS | ESRS (Large) / LSME (Listed SMEs) |
Conclusion: What companies should do now
Despite the massive relief provided by the omnibus directive, there is no reason for suppliers to be idle. Even if companies fall below the new thresholds, their major customers with reporting obligations will continue to demand ESG data from them (trickle-down effect). Therefore, a solid data foundation remains a competitive advantage and meets the requirements of major customers and lenders.