CSRD Omnibus Simplification: What the 2025 Changes Mean for Reporters and How to Pick a Consultant Who Can Navigate Them

If you have been trying to plan a CSRD program over the past twelve months, you have been hitting a moving target. The European Commission's Omnibus Simplification Package, the Stop-the-Clock directive, and the parallel revision of the ESRS standards have changed who has to report, when they have to report, and how much they have to disclose — all while the underlying directive remains in force.

The result is a strange in-between state. Some companies that were preparing for first-time reporting have been pushed back two years. Others are no longer in scope at all under the proposed thresholds, but cannot be sure until the substantive amendments are formally adopted. A third group — typically wave 1 reporters — is already past the point of slowing down and has to keep going.

This guide walks through what the CSRD Omnibus actually changed in 2025, what is still being negotiated, and what a sensible reporting plan looks like in 2026. It also covers how to evaluate a CSRD consultant who can keep you on the right side of a fast-moving regulatory file — which has become the single most important hiring criterion this year.

What Is the CSRD Omnibus Simplification Package?

In February 2025, the European Commission published the Omnibus Simplification Package (often called "Omnibus I"), a bundle of legislative proposals aimed at reducing the reporting burden on EU companies across several sustainability files at once:

The Corporate Sustainability Reporting Directive (CSRD)
The Corporate Sustainability Due Diligence Directive (CSDDD)
The EU Taxonomy Regulation
The Carbon Border Adjustment Mechanism (CBAM)

For CSRD specifically, the Commission proposed three things:

Postpone the reporting obligation for companies in waves 2 and 3 by two years.
Raise the scope thresholds, taking a large share of mid-sized companies out of mandatory reporting.
Revise the ESRS to reduce the number of mandatory data points and clarify the double materiality methodology.

These proposals were not adopted as a single package. Instead, the EU institutions split out the timeline change into a separate fast-track instrument so they could give companies clarity before the next reporting cycle. The substantive scope and ESRS changes have moved on a slower track and remain in negotiation.

This split is the single most important thing to understand about the Omnibus: the timeline relief is law, the scope and content relief is still a proposal.

What Has Already Been Adopted: The Stop-the-Clock Directive

The "Stop-the-Clock" directive (Directive (EU) 2025/794) was adopted in spring 2025 and is the only part of the Omnibus that is currently binding EU law. It does one job, and does it cleanly:

Wave 2 reporters — large companies not previously subject to NFRD, originally required to report on FY2025 — are postponed by two years to FY2027 (first reports published in 2028).
Wave 3 reporters — listed SMEs, originally required to report on FY2026 — are postponed by two years to FY2028 (first reports published in 2029).
Wave 1 reporters — large public-interest entities already subject to NFRD — are not postponed. They continue under the original timeline.

In practical terms, the Stop-the-Clock buys the EU institutions time to finalise the substantive amendments without forcing a wave of companies into mandatory reporting under rules that are about to change. It does not repeal the CSRD, and it does not automatically take any company out of scope.

If you want to see how the new dates fit into the broader compliance picture, see our CSRD implementation roadmap — the phase structure is the same, but the calendar shifts.

What Is Still Proposed (and Likely to Change)

The substantive parts of the Omnibus — the scope thresholds and the ESRS rewrite — were still being negotiated through late 2025 and into 2026. Anything in this section can shift before final adoption, so treat it as direction of travel rather than law.

Scope: Higher Employee Thresholds

The Commission proposed raising the CSRD employee threshold from 250 employees to 1,000 employees, while keeping the EU Taxonomy and CSDDD scopes broadly aligned with the new CSRD perimeter. If adopted as proposed, this would:

Take a large share of mid-cap companies out of mandatory CSRD reporting.
Keep the directive focused on the largest economic actors, which the Commission argues delivers most of the disclosure value.
Push more companies into the voluntary reporting standard for SMEs (the so-called VSME), which EFRAG developed in parallel.

The European Parliament and several Member States proposed alternative thresholds during trilogue. Until the final text is published in the Official Journal, do not assume your scope position is settled.

ESRS: Fewer Mandatory Data Points

EFRAG was tasked by the Commission with delivering a substantially simplified ESRS with materially fewer mandatory data points and clearer guidance on:

How to perform a double materiality assessment without overrunning the project budget
How to define and report on the value chain without requiring data the company genuinely cannot obtain
How to structure narrative disclosures consistently
How to prioritise across the 12 ESRS standards

The expectation across the consulting community is that the revised ESRS will retain the architecture (cross-cutting standards, topical standards, double materiality) while trimming the data-point count. Wave 1 companies should plan to switch to the revised standards once they are adopted, with a transition window.

Value Chain: A Lighter Touch

The Commission also signalled that the value chain reporting expectations would be relaxed for non-listed entities further down the supply chain — broadly, that listed and very large companies cannot pass an unlimited data request down to small suppliers. This is particularly relevant for Scope 3 emissions and ESRS S2 (workers in the value chain).

Assurance: No Move to Reasonable Assurance Yet

Under the original CSRD, the Commission was meant to consider moving from limited assurance to reasonable assurance by 2028. The Omnibus signalled that this move would be deferred — a meaningful relief for companies and for the assurance market. See our guide to CSRD assurance and audit requirements for what limited assurance currently demands.

Who Is Still in Scope in 2026?

This is the question every finance and sustainability lead is asking. The honest answer is: it depends on your wave, your size, and what gets adopted. Here is a working framework you can use today.

If You Are a Wave 1 Reporter (Already Reporting)

You are still in scope. You should continue full implementation under current ESRS, and plan a transition to the revised ESRS once they are adopted. Your priorities:

Stabilise your data collection process and controls.
Strengthen your stakeholder engagement for the next double materiality refresh.
Prepare the team for re-tagging under any revised XBRL taxonomy — see our XBRL guide.
Treat the simplification as an opportunity to retire low-value data points, not a reason to slow the program down.

If You Are a Wave 2 Reporter (Originally FY2025, Now FY2027)

You have two extra years. How you use them determines whether the program is healthy or fragile when reporting starts.

Use 2026 to finish your double materiality assessment and gap analysis — these are the hardest steps and benefit most from time.
Hold off on heavy spend on data-collection tooling until the revised ESRS data points are confirmed.
Reassess your scope position once the threshold change is adopted; you may end up out of mandatory scope and able to report voluntarily under VSME.

If You Are a Wave 3 Reporter (Listed SME)

You have a four-year horizon and the highest probability of falling out of mandatory scope altogether. The pragmatic path:

Maintain a basic sustainability data baseline in case you are required to report — or asked to by a customer.
Track the Omnibus negotiations rather than running a full CSRD program now.
Consider reporting voluntarily under VSME, which is increasingly accepted by banks and large customers as a supply-chain proxy for CSRD readiness.

If You Are Not in Scope but Get Asked Anyway

The most common scenario in 2026 is being a non-EU, sub-threshold, or otherwise out-of-scope company that nonetheless receives a CSRD-style data request from a large customer or lender. The Omnibus has not eliminated this trickle-down effect — it has actually intensified it, because in-scope companies still need value chain data and have fewer ways to require it formally.

A short, well-scoped voluntary disclosure aligned to VSME is usually the right answer. Our SME compliance guide covers this in detail.

What the Omnibus Does Not Change

It is just as important to be clear about what is unchanged:

The CSRD itself remains in force. It has not been repealed and there is no political path to repealing it in the current mandate.
Double materiality remains the foundational methodology. The simplification clarifies it; it does not replace it with single materiality.
Limited assurance is still mandatory for in-scope reporters.
XBRL tagging is still required.
The structure of the ESRS — cross-cutting plus topical, environment / social / governance — is preserved.
Wave 1 reporters continue on the original timeline.

If a vendor or consultant is telling you that "CSRD is dead" or that you can stop your program because of the Omnibus, that is a strong signal to look elsewhere. The directive is alive; the parameters are being tuned.

How to Plan a CSRD Program Through Regulatory Uncertainty

Practitioners have converged on a small set of planning principles that work well when the rulebook is shifting underneath you.

1. Anchor on Materiality, Not on Data Points

A robust double materiality assessment survives almost any version of the ESRS. The data points may shrink, but the material topics will remain material. Invest in materiality first; data point mapping second.

2. Build Reusable Data Infrastructure

Your data collection model — owners, controls, frequency, source systems — is more durable than the specific disclosures it feeds. Design the data collection process once; let the disclosure layer absorb the changes.

3. Sequence Spend Behind Adoption

Defer software licences, deep value-chain data programs, and assurance retainers until you know which version of the rules you are reporting under. Bring forward materiality, governance setup, and team capability building, which are valuable in any scenario.

4. Keep the Governance Structure Intact

Treat CSRD as a permanent change to your governance and disclosure operating model, not a one-off project. Boards, audit committees, and management need to keep the topic on their agenda even if the immediate reporting deadline has slipped.

5. Plan for VSME as a Real Option

For wave 2 and wave 3 companies, VSME is becoming the de facto standard for "I am not legally required, but I am being asked." A consultant who only knows full ESRS — and has never built a VSME-aligned disclosure — is a poor fit for many companies in 2026.

What This Means for Hiring a CSRD Consultant in 2026

The Omnibus has changed what good CSRD consulting looks like. The skills that mattered in 2023 — pure ESRS technical depth — are still necessary, but no longer sufficient. The bar for a useful consultant in 2026 is meaningfully higher in three areas.

Regulatory Fluency

Your consultant should be able to explain, off the top of their head:

The current legal status of each Omnibus element (adopted vs. proposed)
Your wave and likely scope position under both current and proposed thresholds
The implications of the latest EFRAG ESRS revision drafts
How the Stop-the-Clock interacts with national transposition in your Member States

If they cannot, they will not be able to keep your program calibrated as the file evolves. See our questions to ask before hiring — you may want to add a regulatory-tracking question at the top of your list.

Modular Engagement Design

Consultants who insist on a fixed 12-month, full-scope engagement are mispricing the risk in the current environment. Look for engagement models that include:

A short scoping phase that ends with a clear go / hold / scale-down decision
Phase gates aligned to expected adoption milestones of the Omnibus
Clear off-ramps if your company falls out of mandatory scope

This affects pricing too. Our guide to CSRD consultant costs covers typical ranges; expect more proposals to be structured in shorter, gated phases than was common a year ago.

Honest Positioning on Wave and VSME

Consultants who only sell full ESRS programs have an incentive to keep you on a full-ESRS path even if VSME is the right answer. Consultants who can comfortably scope, deliver, and assure both ESRS and VSME engagements are better aligned with where most non-wave-1 companies actually need to go.

The choice between a Big 4 firm and an independent consultant becomes more interesting under the Omnibus. Independents tend to be faster to absorb regulatory changes and more flexible on scope; Big 4 teams have deeper assurance integration and broader bench depth for complex groups. Match the choice to the wave and complexity, not to the brand.

Common Mistakes Companies Are Making Right Now

Across the CSRD programs we see in 2026, a few patterns keep recurring:

Pausing the program entirely. Wave 2 and 3 reporters who stopped all CSRD work after Stop-the-Clock are now scrambling to restart materiality with a much shorter runway than they think.
Assuming the threshold change is law. It is not, yet. Building your scope strategy on a proposal that may move during trilogue is risky.
Buying tooling early. Software roadmaps will move with the revised ESRS. Heavy licence commitments before adoption tend to age badly.
Ignoring VSME. Treating the only options as "full ESRS" or "nothing" leaves a real gap when supply-chain requests arrive.
Letting governance lapse. Disbanding the CSRD steering committee because the deadline moved means rebuilding it from scratch later — usually under time pressure.
Hiring on price alone. Cheap engagements that do not include regulatory tracking quickly become expensive when the rules shift mid-project.

Bringing It All Together

The CSRD Omnibus has not made CSRD easier; it has made CSRD smaller and slower. Smaller in scope, slower in cadence, but no less serious for the companies that remain in it. The directive is intact, the methodology is intact, the assurance regime is intact.

For wave 1 reporters, the message is to keep going and absorb the simplifications as they arrive. For wave 2 and 3 reporters, the message is to use the extra runway intelligently — finish materiality, build reusable infrastructure, and avoid spending into uncertainty. For everyone else, the message is to be ready for VSME-style requests from customers and lenders even if you are not in mandatory scope.

The right CSRD consultant in this environment is not the one with the longest ESRS deck. It is the one who can tell you, with calm specificity, what is law today, what is proposal, and what your sensible next move is given both.

Find a CSRD Consultant Who Can Navigate the Omnibus

The CSRD landscape has changed more in the last twelve months than in the four years before. The CSRD Experts directory lists consultants who actively track the Omnibus negotiations, the EFRAG ESRS revisions, and the Member State transpositions — not just the original 2024 rulebook.

Whether you need a short scoping engagement to confirm your wave and scope position, a full-program partner for wave 1 reporting under current ESRS, or VSME-aligned support to handle inbound supply-chain requests, CSRD Experts helps you find professionals matched to expertise, industry, and company size. Browse the directory to find a consultant who can guide you through a moving target with a steady hand.