CSRD and the Omnibus I package: sustainability reporting refocused
Publication · October 21, 2026
Directive (EU) 2022/2464 of 14 December 2022 (known as « CSRD »), published in the Official Journal of the European Union on 16 December 2022, extended and strengthened sustainability reporting obligations, replacing the regime of the Non-Financial Reporting Directive. Its roll-out was staggered across several waves according to the size and nature of companies. From 2025, however, the European Commission launched a major simplification drive, embodied in the « Omnibus I » package presented on 26 February 2025. This process led to a substantial revision of the regime. The developments below are current as of 21 October 2026; as this is an evolving area, the exact state of the applicable law must be confirmed on a case-by-case basis.
The first part of the package, known as « stop-the-clock », was adopted swiftly: Directive (EU) 2025/794 of 14 April 2025, published in the Official Journal on 16 April 2025, postponed certain deadlines in order to avoid companies becoming subject to obligations that were due to be amended. In concrete terms, the reporting obligations of the second wave (large companies not yet subject) and the third wave (listed SMEs) were postponed by two years. The first wave, composed of companies already subject to the previous regime, was not covered by this postponement. This holding mechanism was intended to secure the transition pending the final adoption of the substantive measures.
The second, substantive part followed a longer legislative path. According to the information available, the substantive simplification directive was published in the Official Journal of the European Union on 26 February 2026 (Directive (EU) 2026/470). It refocuses the scope of the CSRD and, in the same movement, amends other sustainability-related instruments. The numbering and date of publication, as well as the precise date of entry into force, should be verified directly on EUR-Lex, as the area underwent rapid changes during the procedure. Companies should ensure that they are working on the most recent consolidated version of the European texts and their implementing measures.
The main practical consequence lies in the raising of the application thresholds. The regime in principle refocuses the CSRD on companies with more than 1,000 employees and net turnover exceeding EUR 450 million, thereby removing from scope a significant proportion of the companies initially targeted. Specific rules govern the situation of third-country groups with significant activities in the Union. This increase substantially alters the perimeter of companies required to publish a sustainability report. The classification of a given company against the new thresholds, as well as the financial year from which the obligations apply, must be assessed on a case-by-case basis, taking into account national transposition measures.
Belgium had transposed the CSRD by the Act of 2 December 2024 on the disclosure of sustainability information and the assurance of such information. The exact date of publication in the Belgian Official Gazette and the precise references should be confirmed against official sources. The transposition of the « stop-the-clock » component was subsequently carried out in Belgian law at the end of 2025, amending the deadlines set by the Act of 2 December 2024. The adaptations required by the substantive directive published in 2026 still call, as at the date of this note, for careful monitoring: the state of Belgian transposition must be confirmed before any decision, as the texts remain liable to change.
Even refocused, the CSRD retains an indirect effect on SMEs forming part of the value chain of large subject companies, which request sustainability information from their suppliers and subcontractors. To frame this effect, a value-chain protection mechanism has been provided for: a subject company may in principle not require a smaller company to provide information beyond that covered by the voluntary standard for SMEs (known as « VSME »), developed by EFRAG. The status and exact scope of this standard and its implementing measures should be verified, as the corresponding regulatory framework is, as at the date of this note, still being finalised.
In summary, the simplification drive reduces the number of directly subject companies and eases the timetable, without abolishing the sustainability transparency objectives. Companies that fall outside the mandatory scope may nonetheless remain indirectly concerned, through their business partners or their funders, and some may choose to report on a voluntary basis. Given the evolving nature of the area, the dates, numbers and thresholds mentioned should be verified on EUR-Lex and on official Belgian sources before any decision. This note, strictly informative and current as of 21 October 2026, does not constitute personalised legal advice and will need to be updated as the transposition and implementing measures are published.