What CDP’s commercial split means for your disclosure and score
June 25, 2026
The European Council circulated the final compromise text of the Omnibus I Directive on 23 February 2026. The reform is legally settled, and companies waiting for certainty before making decisions about their reporting programmes have it.
What changed?
The threshold for mandatory CSRD reporting now sits at more than 1,000 employees and more than €450 million in turnover, up from 250 employees. Roughly 80 percent of companies previously in scope are no longer subject to mandatory ESRS reporting. Wave 2, covering large undertakings not previously under the NFRD, remains on track for financial year 2027, with first reports due in 2028.
One detail in the Council’s final text differs from the Parliament’s version. The Parliament required the Commission to adopt a voluntary standard for companies below the new threshold. The Council’s text gives the Commission discretion to do so. That standard may still arrive, but it is not guaranteed, and companies below the threshold that continue to receive data requests from customers and investors should not plan around it.
For companies that remain in scope, the obligations have not been reduced in substance. The revised ESRS cuts mandatory datapoints by more than 60 percent, but the fair presentation objective is now stated more explicitly. Reported information must be relevant, complete, neutral, accurate, and verifiable. Audit readiness is part of that requirement, not separate from it.
Our April 2026 webinar covers Omnibus I in detail, including its practical implications for Wave 2 preparation.
“The reform changes who has to report, not what good reporting requires. Companies that remain in scope should not treat simplification as a signal that less rigour is needed.”
– Jatin Budhraja
