If you've been following CSRD developments over the past year, you're familiar with a pattern: a major announcement, a flood of analysis, and then more waiting. Omnibus I broke that cycle. The directive was published in the EU Official Journal on February 26 — the first anniversary of the European Commission's original proposal — and entered into force on March 19, 2026. The law is now final.
As Ropes & Gray put it, channeling Churchill: "Now this is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning."
That's a useful frame for U.S.-based multinationals trying to figure out what to do next.
What Omnibus I actually changed
The headline change is scope. CSRD now applies to EU companies with more than 1,000 employees and net annual turnover above €450 million. For non-EU companies, the threshold is €450 million in EU net turnover at group or individual level, with an additional requirement that an EU subsidiary or branch generated at least €200 million in the preceding financial year. According to Ropes & Gray, these changes reduce the number of in-scope companies by approximately 90% from the original directive.
That's significant. But for U.S. multinationals with meaningful EU revenue or operations, the math still applies and the compliance clock is running.
The Omnibus also ended the phased wave-and-threshold implementation system. Companies that were in Wave 1 — already required to report for financial years starting in 2024 — but no longer meet the revised thresholds are exempt from reporting requirements for financial years 2025 and 2026, subject to national transposition. Wave 2 companies with EU subsidiaries that remain in scope will generally be due to report in 2028 for financial year 2027.
Beyond scope, the Omnibus simplified the underlying reporting standards. The value chain also gets relief: companies with fewer than 1,000 employees are now protected from extensive information requests from larger reporting companies, a change that matters if your suppliers have been anxious about what CSRD would demand of them.
What's still in motion
The law being final doesn't mean companies can begin building their compliance infrastructure in full. That's because the law and the technical reporting standards beneath it are two separate things and only one of them is settled.
The European Sustainability Reporting Standards (ESRS) define exactly what companies must disclose and how. Revised, simplified standards reflecting the Omnibus changes are still being developed by EFRAG and have not been finalized. A draft was published in December 2025, reducing mandatory data points by 61% and eliminating all voluntary disclosures. The European Commission has committed to adopting a final version by September 18, 2026 — six months from the directive's entry into force. The revised standards are then expected to apply beginning with financial year 2027 reporting.
That creates a practical gap: companies know the legal obligation has changed, but don't yet have the full technical detail of what they'll actually need to report. Building out data collection systems, training staff, and structuring internal processes all depend on that detail. The September 2026 deadline for the Commission to finalize the ESRS is a meaningful milestone, but it isn't the finish line — companies will then need time to operationalize standards before FY2027 reporting begins.
Two other items remain in progress:
Member state transposition: EU member states have until March 19, 2027 to transpose the Omnibus I directive into national law. Ropes & Gray's monthly CSRD Transposition Tracker shows meaningful variation in how member states are approaching this. For multinationals with subsidiaries in multiple EU jurisdictions, the national-level details matter: translation requirements, publication obligations, and local filing rules differ by country.
Assurance: The deadline for adopting limited assurance standards has been deferred to July 1, 2027, and the obligation to adopt reasonable assurance standards has been removed entirely. Additional implementation guidance in this area is still forthcoming, particularly relevant for Wave 1 companies already in their reporting cycles.
What this means if you're a U.S. multinational
The revised thresholds may have moved some companies out of scope. If you were borderline before, it's worth a fresh assessment. But if your EU operations or revenue put you above both thresholds, Omnibus clarified your situation.
For Wave 2 companies delayed by the "Stop the clock" directive, the compliance process begins in earnest. The two-year delay bought time. That time is now being spent.
The practical to-do list: confirm whether you're in scope under the revised thresholds, identify which EU member states your operations fall under and what their specific transposition requirements look like, and use the December 2025 draft ESRS to orient your data collection now. Waiting for the September 2026 final version before building any infrastructure is a way to run out of runway before FY2027 reporting arrives.
One more thing worth noting: even companies that fall outside the revised CSRD thresholds may face indirect pressure through their value chains or enterprise customers. That dynamic — and what voluntary reporting can do about it — is worth a separate look.
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