Omnibus I is in force, and roughly four in five previously in-scope companies have fallen out
The Council adopted the final Omnibus I text on 24 February 2026, following the Parliament's approval on 16 December 2025. CSRD now reaches only undertakings with more than 1,000 employees and net turnover above €450 million. Third-country parents are caught at €450 million of EU turnover where they have a subsidiary above €200 million or a branch meeting the threshold. Listed medium-sized and small companies, and financial holding companies, are out. Wave-one companies falling out of scope receive a transition exemption covering 2025 and 2026.
On the due diligence side the CSDDD threshold rises to 5,000 employees and €1.5 billion. The Article 22 obligation to adopt a climate transition plan is removed entirely. Member States transpose by 26 July 2028 and the rules apply from 26 July 2029. A VSME voluntary standard for undertakings outside scope was expected as a delegated act in June 2026, and is the instrument most likely to become the de facto template for value-chain requests.
Falling out of CSRD scope does not remove the underlying data obligation. In-scope customers, lenders and CBAM declarants continue to demand the same emissions and value-chain data through contract rather than through statute. The obligation migrates from regulator to counterparty — and counterparty obligations carry no phase-in, no transition exemption and no proportionality principle.
Re-run the in-scope test at group level and name the internal owner for data and assurance whichever way it lands. Where you have fallen out, expect the first customer data request within the current contracting cycle, and decide now whether you answer it on the VSME template or on an ad hoc basis.
Covered in OGEMEX Regulatory Monitor No. 001, week ending 31 July 2026.