By Thaddée Leblond · Published · Updated: August 2026
Good news for most SMEs: the Omnibus I directive (EU) 2026/470, published on 26 February 2026, has taken them out of the CSRD. By raising the reporting threshold to around 1,000 employees, it exempts roughly 80% of originally-covered companies. But the value-chain effect remains: your large customers keep asking you for ESG data. The safeguard: a value-chain cap now limits their requests to the content of the voluntary VSME standard.
What changed: most SMEs leave the obligation
The CSRD has changed significantly. The "Stop the Clock" directive of April 2025 had already postponed waves 2 and 3 by two years. The Omnibus directive then raised the thresholds — around 1,000 employees combined with a financial criterion — exempting the large majority of originally-targeted companies. Listed SMEs are excluded from the mandatory scope (a simplified optional standard remains available to them). In practice, the mandatory scope now concentrates on very large companies; national transposition is expected by 2027.
Why you are still concerned: the value-chain effect
Leaving the obligation does not mean leaving the pressure. Your customers must report on their value chain — and turn to their suppliers for ESG data. Supplier questionnaires have never circulated so widely. For an SME, the real deadline is not a piece of legislation: it is the day a strategic client makes a contract conditional on your sustainability maturity.
The VSME: your framework and your safeguard
This is the useful innovation of the Omnibus. The VSME standard (a voluntary framework for non-listed SMEs) provides a proportionate reporting format. Above all, the value-chain cap means a large client can, in principle, only require from an SME the information contained in that standard. You therefore have a standard framework to respond with — and an argument to refuse disproportionate requests.
Should you engage anyway?
Yes, out of well-understood self-interest. A structured ESG baseline — a few key indicators, a trajectory, evidence — secures your commercial relationships, eases access to certain financing, and sets you apart. Double materiality, which examines both your company's impact on its environment and the effect of sustainability issues on the company, remains the confirmed analytical standard.
The CSRD's scope and timeline are still being finalised and transposed. Verify your situation against official sources before making decisions.
Frequently asked questions
Most probably not. The Omnibus directive raised the reporting threshold to around 1,000 employees combined with a financial criterion, taking the large majority of originally-covered companies out of scope. The exact scope depends on national transposition, expected by 2027.
Even when not subject, your company receives ESG questionnaires from its large customers, who must themselves report on their value chain. The real deadline is not regulatory: it is the moment your major clients ask you for ESG data.
Partly, yes. The Omnibus introduces a value-chain cap: a large customer can, in principle, only request from an SME the information contained in the voluntary VSME standard. It is both your reporting framework and a safeguard.
It is often in your interest: a structured ESG baseline secures commercial relationships, eases access to certain financing, and differentiates you. Double materiality remains the confirmed analytical standard.
Sources
- European Commission — Omnibus directive (CSRD simplification)
- EFRAG — VSME standard for non-listed SMEs