CSRD Omnibus: what changed and the new timeline

The revised timeline

• Wave one, large listed entities already inside the original CSRD, continue reporting, on financial year 2024 data onward.
• Other large undertakings meeting the revised thresholds of more than 1,000 employees and more than €450 million turnover begin reporting in 2028, on financial year 2027 data.
• Large non EU groups meeting the EU turnover test begin in 2029, on financial year 2028 data.
• Listed SMEs are no longer in scope.

Sector specific standards have been cancelled, and there are new limits on the information large companies can require from smaller value chain partners.

Why 2028 is not far away

If your first report covers financial year 2027, you are reporting on a period that begins in a little over a year. And because the standards require assured data, you cannot start collecting on day one of the reporting year. You need the data pipeline, the controls and the materiality assessment in place before the reporting period starts, so the data you report on has been produced under control from the beginning.

Work backward from a financial year 2027 report and the materiality assessment and data build need to be well advanced during 2026. That is now.

What to do with the time

• Confirm scope in writing. The thresholds changed. Establish clearly whether you are in, entity by entity, and revisit annually.
• Run the double materiality assessment properly. It sets everything downstream and takes months. Do it once, well.
• Map and control your data. The longest lead item by far. Sustainability data that will be assured must be produced with an audit trail from the start of the reporting period.
• Prepare for assurance early. Build the evidence and controls before your assurance provider asks, not during their engagement.

Do not confuse a later deadline with less work

The most common mistake we see now is relief. The deadline moved, so the pressure came off. But the total work did not shrink, only the reporting date moved, and the slowest parts still take the best part of two years. Groups that use 2026 to build the foundation will report calmly. Groups that wait until 2027 will not.

We help groups sequence the work back from their reporting deadline. See CSRD readiness or get in touch.