CSRD sustainability reporting – what is changing under the EU Omnibus?

EU corporate sustainability reporting has undergone a significant change. The European Parliament and the Council have approved the so-called Omnibus I package, which substantially amends both CSRD sustainability reporting and the Corporate Sustainability Due Diligence Directive (CSDDD).

As a result of this update, the scope of CSRD is significantly narrowed, reporting timelines are postponed, and the indirect reporting pressure on SMEs in particular is reduced.

In this article, we explain what CSRD now means, who it applies to, and what the changes mean for companies in the food value chain.

What is CSRD?

CSRD (Corporate Sustainability Reporting Directive) is an EU directive that requires certain companies to report on their sustainability impacts as part of their annual reporting.

Reporting is based on the ESRS standards (European Sustainability Reporting Standards) and covers, among other things:

• climate emissions (Scopes 1–3)
• impacts on natural resources and land use
• social and governance factors
• risks, impacts and opportunities (double materiality)

Who does CSRD actually apply to now?

After the Omnibus I reform, CSRD reporting obligations apply only to the very largest companies.

New CSRD scope

A company falls within the scope of CSRD only if both of the following criteria are met:

• more than 1,000 employees, and
• more than €450 million in net turnover

This applies to:

• companies headquartered in the EU
• non-EU companies that:
  • generate more than €450 million in turnover in the EU for two consecutive years, and
  • have an EU subsidiary or branch with turnover exceeding €200 million

When does reporting start?

• The first CSRD reporting year is 2027
• Sustainability reports will be published in 2028

Companies that were already subject to CSRD (so-called “wave 1” companies) but fall outside the new thresholds may still be required to report until 2027, unless exempted by national legislation.

Good news for SMEs: limits on value chain data requests

One of the most important Omnibus changes concerns the value chain.

Cap on value chain data requests

Companies with:

• fewer than 1,000 employees

may refuse additional data requests made for CSRD reporting purposes if they exceed the requirements of the voluntary reporting standards (VSME).

👉 In practice, this means that large companies can no longer shift CSRD reporting obligations indefinitely onto smaller suppliers.

Companies may also provide a self-declaration, which the reporting company does not need to verify unless it is clearly incorrect.

That said, collecting sustainability data remains important in practice — particularly for access to financing, achieving emission reduction targets, and developing business operations.

Flexibility in data collection and exemptions

CSRD now includes several reliefs:

If not all value chain data can be obtained, companies may, for the first three years, explain:

• why the information is not available
• what efforts have been made
• how data collection will be developed going forward

Certain information may be omitted if:

• it would jeopardise trade secrets
• it is confidential or classified
• it relates to security or privacy concerns

What about sector-specific ESRS standards?

The original CSRD included plans for mandatory sector-specific ESRS standards.

🔔 These have now been removed.

They are replaced by:

• voluntary sector-specific guidance,
• with no binding reporting requirements.

This is particularly important for the food sector, where reporting practices are still evolving.

In brief: CSDDD (Corporate Sustainability Due Diligence Directive)

Omnibus I also significantly amended the CSDDD:

• Applies only to companies with:
  • more than 5,000 employees, and
  • more than €1.5 billion in turnover
• The mandatory transition plan requirement was removed at EU level
• Due diligence obligations remain risk-based
• The maximum penalty level was reduced to 3% of global turnover

CSDDD will apply no earlier than 2029.

What does this mean in practice?

• Most SMEs are not subject to CSRD
• Reporting pressure in value chains is significantly reduced
• Nevertheless:
  • customer requirements
  • SBTi targets
  • product-level carbon footprints continue to make climate data business-critical.

👉 CSRD is no longer the primary driver for everyone — but reliable emissions data remains a competitive advantage.

How does Biocode help?

Biocode supports companies with:

• product carbon footprint calculations
• Scope 1–3 emissions accounting
• preparation for SBTi and FLAG requirements
• food value chain data collection without heavy manual work

📩 Get in touch if you want to understand what reporting or calculation is truly relevant for your company.