CSRD reporting after Omnibus: where things stand now

Published: 2026-09-07

⏲ Read time: 5 minutes

Few companies have been able to plan their sustainability reporting in peace over the past few years. CSRD was adopted in December 2022, entered Swedish law on 1 July 2024, and had barely begun to apply before the EU's Omnibus package substantially changed the rules. When the amending directive entered into force on 18 March 2026, many companies were left holding finished processes, collected data and a published report. And a new question: does this still apply to us?

This summer brought several of the answers. Here is what has changed, who is in scope, and what it means for the next annual report.

What CSRD is, and what has happened since 2022

CSRD, the Corporate Sustainability Reporting Directive, is the EU's directive on sustainability reporting. The idea was that sustainability information should meet the same standard as the financial figures: comparable across companies and subject to assurance by the auditor. Around 50,000 European companies were to be covered.

Then the political climate shifted. The Draghi report identified regulatory burden as a problem for European competitiveness, and in February 2025 the Commission presented its Omnibus package. After a year of negotiations it was adopted in December 2025 and entered into force on 18 March 2026. What remained was a considerably smaller framework than the one companies had prepared for.

Who is in scope

The requirement was originally to be phased in step by step, reaching companies with more than 250 employees and eventually listed small and medium-sized companies as well. After Omnibus, more than 1,000 employees and net turnover above EUR 450 million are required. Both conditions must be met. The Commission itself estimated that around 80 percent of companies would fall out of scope under its initial proposal. The final directive went further still.

In Sweden, the government inquiry submitted its proposal in April 2026. Sweden is to implement at the EU minimum, without national additions, and the requirement is to apply to companies with more than 1,000 employees and turnover above SEK 4.9 billion in each of two consecutive years. The legislative amendments are proposed to enter into force on 1 January 2027, but to apply to financial years beginning after the end of 2025. The consultation period closed on 21 August and no government bill has yet been submitted.

That last detail matters more than it sounds. Swedish companies with calendar year-ends reported for the first time for 2025, with reports published this spring. If they fall below the new thresholds, they do not need to report for 2026, even though they were required to do so the year before. For many, this spring's report will therefore be both the first and the last.

Changes to the reporting itself

For those still in scope, the report looks much as before. It is the content that shrinks, and since this summer we know by how much.

The Commission adopted the revised ESRS as a delegated act on 3 July 2026, C(2026) 5010 final. The number of mandatory datapoints falls by 61 percent compared with the 2023 standards, and the total number by just over 70 percent. The standards are to apply from financial year 2027, provided neither the Parliament nor the Council objects during the scrutiny period. Companies that wish to may start earlier, either by applying them in full or by staying with the 2023 standards while still cherry-picking the new reliefs.

For 2026, no one needs to expand their reporting. Wave one companies can keep the same scope as before. The figures must of course relate to the correct year, but the number of disclosures need not grow while the new standards are pending.

Three further things fell away along the route. The auditor's review remains at limited assurance, and the plans to raise it to the same level as the audit of the financial statements have been dropped. The sector-specific standards were scrapped before they were ever introduced. And large companies may no longer push their data requirements down the supply chain: from smaller business partners they may only request what falls within the voluntary standard the Commission adopted alongside ESRS.

What this means for the next annual report

The picture differs sharply depending on which side of the threshold a company lands. Companies still in scope first need to decide which standard this year's report will follow. For 2026, the options are to stay with the 2023 ESRS, to do so while cherry-picking the new reliefs, or to move straight to the 2026 standards. Raise it with the auditor early. The choice determines what the review covers, and it is not something you want to be sorting out in February.

Then comes the review of the content itself. When six in ten mandatory datapoints disappear, large parts of the data collection built up over recent years can be dismantled. But it is not self-evident that they should be. Some of the disclosures are used internally for steering. Others are what investors ask for. And removing them breaks the comparison with prior years. It is worth separating what must be reported from what you want to keep for other reasons.

The materiality assessment also needs revisiting. It governs which parts of ESRS become relevant, and when the standards change the answer may come out differently even though the business has not.

Companies falling below the threshold face a different question: what happens to the sustainability section of the next annual report? The legal requirement disappears, but the 2025 report is published and the market has grown used to the information. They can continue applying ESRS voluntarily, move to the voluntary standard the Commission has adopted, or scale back to a shorter section without any standard.

Which route is right depends on who actually reads the report. Banks' credit processes, customers' procurement requirements and investors' questionnaires do not go away because the legal requirement does. At the same time, those requirements are usually considerably easier to meet than full ESRS reporting.

The sustainability report is produced in the same process as the financial part of the annual report, often by several functions working in parallel and under time pressure. The more of the figures that are drawn from a single source, the less work is created when the underlying data changes late, which it often does. That is one reason more companies are moving production into a single connected digital workflow rather than separate documents.

One thing applies to both groups: timing. The sustainability report forms part of the management report and follows the annual report process, so the decision needs to be made before production begins. It is trickiest for companies close to the thresholds, since Swedish law will not be settled until Parliament has dealt with the government bill.

Summary

After Omnibus, the requirement covers companies with more than 1,000 employees and turnover above EUR 450 million. In Sweden, thresholds of 1,000 employees and SEK 4.9 billion are proposed, applying already for financial year 2026.
The consultation period closed in August and no government bill has yet been submitted.
The Commission adopted the revised ESRS on 3 July 2026.
The number of mandatory datapoints falls by 61 percent, and the standards are to apply from financial year 2027.
For 2026, no one needs to expand their reporting. The choice is between keeping the 2023 standards, using the new reliefs, or moving across in full, and it should be discussed with the auditor early.
Companies below the thresholds escape the legal requirement but not their customers' and banks' questions. The decision on voluntary reporting needs to be made before work on the next annual report begins.

Sources

CSRD reporting after Omnibus: where things stand now