The Omnibus Delay: A Chance to Prepare, not a Reason to Pause
The Corporate Sustainability Reporting Directive (CSRD) is already transforming how European businesses handle sustainability reporting. For companies in Wave 1, which includes large public-interest entities (such as listed companies, banks, and insurers with over 500 employees), the first CSRD reports are due this year, based on 2024 data.
For companies in Wave 2, defined as large unlisted companies that meet at least two of these criteria: more than 250 employees, €40 million turnover, or €20 million in total assets, the first CSRD reports are scheduled for 2026, based on 2025 data. However, the path to compliance has been more challenging for this group, given resource constraints and tight timelines.
Wave 3 covers listed SMEs exceeding two of these thresholds: more than 10 employees, €900k turnover, or €450k total assets. Their reporting is scheduled for 2027 (on 2026 data), though an optional deferral to 2029 is available to ease the pressure.
Recognizing concerns about tight deadlines and heavy reporting burdens, the European Commission introduced the Omnibus Proposals, aimed at providing relief without losing sight of transparency goals.
But what exactly are these proposals? And why is it still important to act now?
Why Were the Omnibus Proposals Introduced?
In simple terms, the Omnibus Proposals are a response to feedback from businesses. Many argued that the original CSRD timelines were too aggressive, especially for smaller companies with limited resources.
The proposals aim to strike a balance: simplifying requirements and giving companies more time to prepare, while ensuring that sustainability reporting remains a core expectation in the European market.
The Three Key Changes
The Omnibus Proposals introduce three key adjustments that primarily affect companies in Wave 2 and Wave 3:
A two-year delay in CSRD reporting obligations, easing immediate compliance pressure for affected companies.
An increase in the employee threshold for mandatory reporting, raising it from 250 to 1,000 employees and potentially shifting some companies out of scope.
Simplification of ESRS data points, reducing the reporting burden while maintaining transparency standards.
While these changes offer breathing room, stakeholders such as investors, banks, and supply chain partners will continue to expect ESG data and disclosures.
Why ESG Still Matters: Beyond Compliance
Even if your company benefits from the delay or falls below the new thresholds, expectations from investors, banks, and supply chain partners remain. Transparency around sustainability is now a baseline for doing business, not just a legal checkbox.
That’s why the European Commission is also working on a Voluntary Sustainability Reporting Standard (VSME) for SMEs. Opting into such frameworks can help companies maintain credibility and support long-term business value.
The Real Challenge: Data, Not Regulations
Many companies’ approach ESG reporting with a compliance-first mindset, doing the bare minimum to meet regulations. Others see it as a strategic investment, integrating sustainability into decision-making to drive efficiency, innovation, and brand strength.
But the biggest hurdle is rarely understanding the rules. It’s about managing the data: collecting it, aligning it, and using it effectively across the business.
This is where a bottom-up approach becomes crucial. While compliance frameworks are important, companies need to focus on building a solid, scalable ESG data foundation to support both current and future requirements.
Don’t Waste the Extra Time
The Omnibus Proposals give companies more time, but waiting until the last minute comes with risks:
Rushed implementations can be costly and inefficient.
Poor data quality undermines reporting credibility.
Late starters may miss out on strategic benefits like operational efficiencies and risk reduction.
Rather than pausing efforts, now is the ideal time to:
Define your ESG vision.
Pilot solutions and validate your data approach.
Build the right foundations to adapt to evolving regulations.
Final Thoughts
“Stop the clock” does not mean “stop your ESG journey.” Companies that invest in their ESG data processes today will not only ensure smoother compliance tomorrow but also unlock valuable insights for smarter business decisions.
The question is no longer if you should act, but when you start building your ESG data foundation.
