§ 01 · The post-Omnibus landscape

The thresholds that now define who has to file.

The Omnibus I package, formally approved on 16 December 2025, made three substantive changes to CSRD’s scope.

First, the headcount threshold. Under the original directive, any large company meeting two of three criteria — more than 250 employees, more than €25 million in balance-sheet total, or more than €50 million in net turnover — was captured. The Omnibus raises the employee threshold to 1,000+ and the turnover threshold to €450 million. Both must now be met simultaneously rather than as alternative tests. This is the single most significant change. The European Commission’s own impact assessment estimated the new thresholds would remove roughly 80% of previously in-scope companies from mandatory reporting.

Second, listed SMEs are no longer in mandatory scope. The third wave of CSRD, which would have brought listed small and medium-sized enterprises into reporting from FY 2026, has been removed entirely. Listed SMEs may still choose to report voluntarily — and many will, because their institutional investors will require it — but there is no statutory obligation.

Third, the timelines for Wave 2 have shifted by two years. Large non-listed EU companies meeting the new thresholds were originally due to begin reporting on FY 2025 data in 2026. That deadline now moves to FY 2027 data, with reports published in 2028. The first publication year of revised, simplified ESRS standards is expected in the second half of 2026.

Non-EU companies operating in the EU also see threshold revisions. The €150 million in EU-generated net turnover threshold is replaced with €450 million, with subsidiary or branch thresholds rising to €200 million. The first reporting year for non-EU multinationals remains FY 2028, reports published in 2029.

The net effect for industrial operators is straightforward. If your company is a self-standing industrial SME with fewer than 1,000 employees, you are not required to file a CSRD report. If you are a subsidiary of a larger group that crosses the thresholds at the parent level, you may still be captured through the parent’s consolidated reporting, but your obligations are determined by the parent rather than by your own size.

§ 02 · What “not in scope” actually means

The indirect obligation is now the real one.

Reading the Omnibus revisions in isolation suggests that most industrial SMEs can stop thinking about CSRD entirely. This is the wrong conclusion, and the reason is structural rather than legal.

CSRD requires in-scope companies to report not just on their own operations but on their value chain — the suppliers, sub-contractors, and partners whose activities are embedded in the in-scope company’s products. The European Sustainability Reporting Standards (ESRS) require disclosure of Scope 3 emissions, workforce conditions in the value chain, environmental impacts of upstream and downstream activities, and resource flows through the supplier base. The Omnibus revisions softened these value-chain requirements somewhat — in particular by allowing the use of estimates and proxy data where direct value-chain data is unavailable — but the underlying obligation remains. A large industrial group has to report on what its suppliers do.

In practice, this means that any industrial SME selling to a Wave 1 or Wave 2 customer will receive sustainability data requests. The frequency, format, and depth of these requests vary considerably. Some buyers will send a brief questionnaire once a year. Others will require detailed monthly emissions data, certifications for materials and labour conditions, and audit trail documentation. The buyer’s sustainability team is operating under regulatory pressure that the supplier is not, but the data still has to come from somewhere, and the supplier is the only place it can come from.

For industrial SMEs, the practical question has shifted. It is no longer “do I have to file a CSRD report?” — for most operators the answer is now clearly no. The question is “what data will my customers ask me for, in what format, on what timeline?” The answer depends on which customers you serve and how aggressive their own compliance teams are.

There is also a temporal dimension worth noting. The Omnibus changes are not yet fully transposed into the national law of every Member State. Transposition is required by 19 March 2027. Until then, some Member States may operate under the original CSRD thresholds, and some buyers may continue to request data based on the original timelines because their own programmes were built to that schedule. The regulatory uncertainty is real, and any supplier that pauses sustainability data work in anticipation of full Omnibus implementation is taking on risk that the practical demand simply will not slow down.

§ 03 · What an SME should actually prepare

A working preparation list for industrial SMEs.

For industrial SMEs that are not in direct CSRD scope but expect customer data requests, the preparation work is materially lighter than full CSRD compliance but is not zero. The goal is to be able to answer common buyer questions accurately, quickly, and with documentation that survives a buyer’s assurance audit.

The substantive areas where data requests almost always land are: energy consumption broken down by carrier (gas, electricity, oil, biomass), Scope 1 and Scope 2 emissions calculated using a defensible methodology, water consumption in water-stressed regions, waste streams and recovery rates, and basic workforce information including headcount by function, gender breakdown, and any reportable health-and-safety incidents.

The checklist below covers what a self-aware industrial SME should be able to produce on request without scrambling. None of these items requires CSRD-level rigour or third-party assurance; they require ordinary operational hygiene and a defensible method behind each number.

§ 04 · Where it gets harder

Three problems that are not obvious until they happen.

Problem one: incompatible questionnaire formats. Different buyers use different sustainability reporting platforms — CDP, EcoVadis, Sedex, IntegrityNext, NQC, and a dozen smaller systems. Each platform asks the underlying questions in a slightly different format and weighs them differently. An industrial SME selling to ten large customers may receive ten different questionnaires, each requiring 20 to 60 hours to complete properly. There is no clean way to solve this beyond accepting the cost and building a master internal data file that can be re-formatted for each platform’s requirements.

Problem two: Scope 3 data requests that exceed your visibility. Some buyers will request emissions data for individual products you ship to them, broken down by raw material origin. This requires upstream emissions data from your own suppliers, who in turn require data from their suppliers, and so on. The supply chain transparency that CSRD assumes does not yet exist in most industrial sectors. Spend-based estimation using industry-average emission factors is the practical answer; some buyers will accept this, others will push for primary data, and the gap is the source of most operational friction in supplier reporting.

Problem three: the buyer changes their methodology. A buyer may move from spend-based to activity-based emissions calculation in their own reporting, which means your prior data submissions are suddenly inadequate and you have to redo them in a different format. There is no fix for this beyond keeping the underlying data in a structured, transformation-friendly form — ideally in a small database rather than a spreadsheet, so that recalculations are possible without re-collecting the source data.

§ 05 · Bottom line

Three operational rules for industrial SMEs in 2026.

Rule one: build the basic dataset whether or not you are in scope. Energy consumption broken down by carrier, Scope 1 and 2 emissions with a defensible method, water and waste figures, basic workforce data. This is a few weeks of organisational work that pays for itself the first time a buyer sends a questionnaire.

Rule two: do not invest in CSRD-grade reporting infrastructure unless you are in direct scope. The full CSRD reporting machinery — materiality assessments to ESRS depth, double-materiality methodology, ESRS-aligned digital tagging, limited assurance engagement — is genuinely expensive. For an SME that is not in scope, this expense is wasted. Build the underlying data well; do not build the reporting frontend that you are not legally required to produce.

Rule three: track which of your customers cross the thresholds. If a major customer is in Wave 1 or moves into Wave 2 from FY 2027, expect data requests to intensify in the run-up to their reporting deadline. Knowing which customers are in scope, and when, lets you anticipate the pressure rather than respond to it under deadline. A simple spreadsheet listing your top 20 customers and their CSRD status is sufficient.

The Omnibus revisions have made CSRD more pragmatic. They have not made the underlying market pressure for sustainability data go away. Industrial SMEs that build the working data infrastructure now — quietly, without the overhead of full CSRD compliance — will find that the next three years of customer questionnaires, supplier audits, and procurement requirements are mostly an exercise in re-formatting data they already have. The ones who treat the threshold change as a reason to defer the work entirely will find themselves doing it anyway, under deadline, badly, while losing contracts to suppliers who got there first.