linkedin

Update 2026: New CSRD Thresholds & CSDDD Changes via EU Omnibus Directive

The EU limits the direct reporting obligation to companies with 1,000 (CSRD) or 5,000 employees (CSDDD), respectively, in order to reduce bureaucratic hurdles. Nevertheless, smaller suppliers should also rely on standardized ESG data. This report explains why.

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:

  1. Higher hurdles Only large companies with more than 5,000 employees and about 1.5 billion € revenue fall directly under the EU directive.
  2. Uniform start date The application start has been set for all affected companies to the July 26, 2029 postponed.
  3. 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

CriterionBooth 2024Update 2026
CSRD Focusstaggered from 250 employees / 40 million € revenueFrom 1,000 MA / 450 million € revenue
CSDDD FocusFrom 1,000 MA / 450 million € revenueFrom 5,000 employees / €1.5 billion in revenue
Start Date CSDDDPhased in starting 2027Uniform July 26, 2029
Legal certaintyDrafts / NegotiationsOmnibus Directive 2026/470
Reporting StandardFull ESRSESRS (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.

Free initial consultation

Analyze load profile & location — find the most cost-effective energy solution in 30 minutes.

We analyze your location, load profile, and procurement costs independently of manufacturers. You will find out immediately how PV and battery storage systems can reduce your grid costs and make optimal use of regulatory deadlines (EnWG, EPBD) – without technical risk or capital investment.

Keep an eye on regulations and deadlines · Incl. 250+ simulation variants · Free & without commitment

More interesting articles

BiPV-Header

BiPV at a Glance

Thanks to modern technologies, BiPV can now be integrated into architecture in a way that is virtually invisible, thereby significantly improving the ESG rating of real estate. Despite more demanding design requirements, building-integrated photovoltaics offer a future-proof solution for meeting solar installation requirements and achieving climate goals through material savings and the efficient dual use of urban space.

Read more "
Industrial electricity price from 2026

A 5-cent industrial electricity rate starting in 2026?

Only those sectors with a high risk of relocation will benefit retroactively from the industrial electricity price starting in 2026. Since only defined consumption shares are subsidized and funds are decreasing until 2028, the expansion of self-supply through PV and BESS remains the crucial lever for permanently low energy costs.

Read more "
PV-Zubau-2024-gestiegen

PV additions increased again in 2024

With a record addition of 16.2 GW, total solar power capacity increased to nearly 100 GW in 2024. Low module prices and accelerated procedures drove the expansion, with Bavaria remaining the leader at 4 GW and balcony power plants doubling their share to 400 MW.

Read more "
Solar carports - aerial view

Newsletter registration