On 18 March 2026, the Omnibus I Directive ((EU) 2026/470) entered into force. This directive amends the CSRD and the CSDDD with the aim of reducing the reporting burden and simplifying their application. In this Quick Read, we outline the key changes and discuss what they mean for asset managers.
This article is a follow-up to: Quick Read: what you need to know about the Sustainability Omnibus Package (dated March 3rd 2025)
The scope of the CSRD is significantly reduced. The reporting obligation will apply to:
Listed SMEs and financial holding companies fall outside the revised CSRD scope.
Some undertakings are already reporting for the 2024 financial year under the CSRD (the so-called Wave 1 undertakings). A number of these will fall outside the revised scope due to the new thresholds and will therefore no longer be required to report in the future.
Member States may exempt these Wave 1 undertakings from reporting for 2025 and 2026, so that companies falling out of scope are not temporarily subject to CSRD obligations.
The Omnibus Directive introduces a voluntary VSME reporting standard (Voluntary Standard for non-listed micro, small and medium-sized entities). This standard is intended for organisations that are not (or are no longer) subject to the CSRD but still wish to report sustainability information within a simplified framework.
Instead of the hundreds of datapoints required under the CSRD, the VSME standard includes approximately 60 datapoints, significantly reducing the reporting burden.
The Omnibus Directive removes the obligation for the European Commission to adopt sector-specific ESRS standards. Instead, the Commission may publish practical sector guidelines to support the application of existing standards.
The current ESRS will also be simplified: fewer datapoints, greater focus on material information, a clearer distinction between mandatory and voluntary disclosures, and increased emphasis on quantitative reporting. The revised ESRS have not yet been finalised; the Commission is expected to adopt them by mid-2026 via a delegated regulation. Until then, the existing ESRS remain applicable.
There are, however, temporary relaxations through the so-called “quick fix ESRS”, allowing Wave 1 undertakings to omit certain disclosures for the time being.
To prevent smaller undertakings in the value chain (with fewer than 1,000 employees) from being overwhelmed by ESG data requests from larger CSRD-scope companies, the Omnibus Directive introduces a safeguard clause.
Undertakings covered by this clause may refuse information requests from CSRD-reporting companies if those requests go beyond what may be required under the VSME standard.
This rule aims to limit the so-called “trickle-down effect” in the value chain—preventing large companies from effectively passing on their reporting obligations to smaller entities.
The scope of the CSDDD is also reduced. The directive will now apply only to the very largest undertakings: those with more than 5,000 employees and a net turnover exceeding €1.5 billion.
For non-EU undertakings, the directive applies if they generate more than €1.5 billion in net turnover within the EU.
Under the current CSDDD, companies must both adopt and implement a climate transition plan. This obligation is removed under the Omnibus Directive.
The CSRD still requires companies to disclose whether they have a transition plan and the content of that plan. However, unlike the original CSDDD, the CSRD only requires transparency—not actual implementation.
Due diligence obligations become more risk-based. Companies are no longer required to assess their entire value chain in detail. Instead, they may begin with a high-level assessment based on available information to identify the most likely and severe risks.
Only these risk areas require in-depth investigation. Information may be requested from value chain partners only where necessary; from partners with fewer than 5,000 employees only where the information cannot reasonably be obtained otherwise. This reduces the burden on smaller undertakings.
The CSRD amendments must be transposed into national law within twelve months of entry into force. This means the revised rules are expected to apply from financial years starting on or after 1 January 2027, with first reports published in 2028.
To date, the Netherlands has failed to implement the CSRD, which should have been transposed by 6 July 2024. The implementation bill was only submitted to the House of Representatives on 13 January 2025.
On 9 February 2026, the Minister of Finance indicated that certain reporting obligations may apply retroactively from the 2024 financial year. A remedial provision will therefore be introduced: companies that have already reported voluntarily under the CSRD will be deemed compliant with the final rules. If the law does not enter into force before 1 October 2026, this will also apply to the 2026 financial year.
As the bill became outdated, it was agreed to postpone its parliamentary treatment until the final Omnibus Directive was adopted—which has now occurred. It is hoped that the legislative process will now accelerate.
As noted, Member States may decide whether to exempt Wave 1 undertakings that will fall out of scope from reporting for 2025 and 2026. It remains unclear whether the Netherlands will make use of this option.
For the CSDDD, Member States must transpose the directive by 26 July 2028, with companies required to comply from 26 July 2029.
Although the Netherlands previously consulted on the International Responsible Business Conduct Act (WIVO), this process has been put on hold due to Omnibus developments. It is expected that implementation will take place through a new or amended legislative framework.
Let us start with the (expected) good news. Due to the simplification and higher thresholds of the CSRD and CSDDD, the impact on smaller undertakings is limited. However, as an asset manager, you may receive less information overall—but the information received from CSRD-reporting companies is likely to be more reliable and relevant.
At the same time, the revised rules introduce new challenges. As value chain partners are required to provide less—or sometimes no—data, inconsistencies and data gaps may arise. In other words, you may have less data available than before.
Uncertainty around Dutch implementation adds further complexity. It is not yet clear whether Wave 1 undertakings that fall out of scope from 2027 will be exempt from reporting in the interim years. As a result, it remains uncertain whether you can rely on their sustainability data during that period.
Many parties—particularly SMEs that are not subject to the CSRD—are likely to adopt the VSME standard, especially where investors request it. Whether this will be sufficient in practice remains uncertain, as does whether VSME datapoints provide sufficient depth for asset managers, particularly those managing net-zero funds.
It is also relevant to recall that the original CSDDD required companies to develop and implement Paris-aligned climate transition plans. By contrast, the CSRD only requires disclosure of whether such a plan exists and its content. There is no obligation to implement it, which is likely to result in less decision-useful data for net-zero strategies.
Where ESG data is lacking, asset managers may need to invest in additional data collection to substantiate their sustainability objectives and fund strategies. This may require reviewing contracts with data providers and internal processes, including:
A timely review will help mitigate data gaps and ensure better preparedness for the expectations of supervisors, investors and other stakeholders.
Would you like to understand which obligations apply to you, or how these changes may affect your policies, processes or products? Please feel free to contact one of our specialists.
