Background: from very broad scope to selective coverage
As first adopted, CSRD expanded sustainability reporting across large listed and non-listed companies, including phased waves for smaller listed entities and certain third-country groups. That design implied a steep increase in the number of undertakings preparing European Sustainability Reporting Standards (ESRS) disclosures. Political concern about administrative burden led first to a timing adjustment, then to a structural shrink in the set of in-scope companies. The CSRD overview in our European Union library tracks the current summary for operators.
Stop-the-Clock and Omnibus I: the legislative sequence
Directive (EU) 2025/794 (Stop-the-Clock)
Directive (EU) 2025/794 entered into force on 17 April 2025. It postponed parts of the CSRD phase-in so that undertakings in the second wave (large non-listed EU companies that were not public-interest entities) would apply the standards for financial years starting on or after 1 January 2027, with reports due in 2028 instead of the earlier rhythm. Listed small and medium-sized enterprises in the third wave were similarly pushed so that application begins for financial years starting on or after 1 January 2028, with reporting in 2029. The first wave (large public-interest entities already subject to enhanced reporting) was not postponed under that adjustment.
Directive (EU) 2026/470 (Omnibus I)
Directive (EU) 2026/470, the first Omnibus amending CSRD, was published on 26 February 2026 and entered into force on 18 March 2026. It amends the scope articles so that far fewer EU undertakings fall within mandatory ESRS reporting, while leaving the technical reporting toolkit largely intact for those that remain covered.
Who must report after Omnibus I
EU undertakings: combined employee and turnover test
Under the revised CSRD scope, an EU undertaking is generally in scope only where it exceeds both of the following on a consolidated basis: more than one thousand employees on average over the financial year, and more than four hundred and fifty million euros in net turnover. Requiring both criteria together removes many mid-sized groups that would have qualified under employee-only tests, which is why policymakers describe roughly an eighty to ninety percent reduction in the number of companies caught compared with the pre-Omnibus design. Listed companies continue to be assessed with reference to the Accounting Directive size criteria where those rules are cross-referenced, but the Omnibus lifts many smaller listed groups out of mandatory CSRD. Voluntary opt-in remains available for undertakings that want ESRS disclosures for capital markets or supply-chain pressure even when not legally required.
Third-country (non-EU) groups
The Omnibus recalibrates when non-EU undertakings must publish CSRD-style sustainability statements at the level of the EU group or designated subsidiary. The political agreement focuses the obligation on groups with very substantial EU revenue, including a net turnover threshold of four hundred and fifty million euros generated in the EU for the ultimate parent, together with a material EU subsidiary or branch generating at least two hundred million euros net turnover in the Union (measured over consecutive years as defined in the directive text). Exact legal tests should always be confirmed against the Official Journal wording and consolidated accounting boundaries.
What the Omnibus removed and what it kept
Withdrawn or relaxed elements
The Omnibus package withdrew certain sector-specific ESRS exposure drafts from the mandatory set, reducing the expectation that every in-scope reporter would publish the full suite of sector standards on day one. It also stepped back from mandatory company-level climate transition plan disclosures that had been tied to the Corporate Sustainability Due Diligence Directive (CSDDD) interface, so CSRD and CSDDD no longer stack that particular obligation in the same way as under the pre-Omnibus linkage. Sector reporting and transition planning can still matter commercially and under other instruments, but the mandatory CSRD package is lighter in those dimensions.
Retained: limited assurance, digital tagging, and ESRS
For undertakings still subject to CSRD, the baseline remains demanding: limited assurance on sustainability reporting is still phased in, digital tagging under the European Single Electronic Format (ESEF) architecture continues to be part of the disclosure infrastructure, and the ESRS framework (including climate and cross-cutting standards) stays the technical backbone. If you are in scope after Omnibus I, you still need audit-grade processes, structured data, and ESRS-aligned content; you are simply less likely to be in scope at all.
CSDDD, transposition, and impact on venues and host cities
Corporate Sustainability Due Diligence Directive (CS3D)
Parallel Omnibus adjustments to the Corporate Sustainability Due Diligence Directive raise the bar for mandatory due diligence to undertakings with at least five thousand employees and more than one and a half billion euros worldwide net turnover (with EU revenue thresholds for non-EU parents). That narrows the population subject to statutory human rights and environmental due diligence chains. Venue operators and event businesses should still map whether they sit above those thresholds or appear as critical suppliers to companies that do.
Member State transposition by 19 March 2027
Member States must transpose the Omnibus CSRD amendments by 19 March 2027. National gold-plating or guidance can add interpretive detail, so groups operating across borders should monitor both Brussels-level text and domestic implementations. If you previously prepared for CSRD under the old thresholds, keep data systems warm: value-chain requests from banks, sponsors, and large customers did not disappear because the legal net narrowed.
Venues, sports, events, and municipalities
Many standalone venues, clubs, and municipal venue companies will fall below the combined employee and turnover test, particularly where operations are fragmented across legal entities. Listed sports holding groups, global promotion companies, and large infrastructure concessionaires may still clear the bar. Even when you are out of scope, lenders, insurers, league partners, and EU sponsors may continue to ask for ESRS-shaped datasets for their own SFDR or CSRD reporting. Cities that own major companies (energy, transport, arena management) should run a fresh group consolidation check after Omnibus I.
- Treat CSRD scope as a legal test, not a proxy for whether stakeholders will request the same data.
- Align GHG inventory boundaries with ESRS E1 expectations when you supply upstream reporters.
- Watch national transposition for reporting formats, assurance timelines, and penalty rules.
How 50X Impact helps
Scope decisions, then deterministic ESRS-grade evidence
50X Labs built 50X Impact so venues, sports, events, and municipalities can maintain one verified data spine whether they are primary CSRD reporters or answering downstream questionnaires. When you are in scope, limited assurance and digital tagging mean traceability from source systems to disclosed lines is non-negotiable. When you are not, the same platform supports voluntary ESRS-aligned packs and “Digital Twin”-backed energy and mobility metrics so partner audits stay lightweight.
Revisit the live summary in our CSRD policy card for headline thresholds alongside this article.