ESG

Omnibus cut CSRD’s scope by about 85%. Your customers’ ESG questionnaires did not stop

The EU narrowed who must report. It did not narrow what your customers ask you for. A plain reading of the Omnibus for suppliers.

By Brahim Eloidii, Co-Founder, ESG & CSR Lead

Published 10 October 2026 · Sources last checked 16 October 2026

What changed

Directive (EU) 2026/470, known as Omnibus I, entered into force on 18 March 2026. Member States must transpose its amendments by 19 March 2027.

• CSRD: the revised scope generally requires both more than 1,000 employees and net turnover above EUR 450 million. The Commission estimates that this removes about 85% of the companies originally expected to report. That figure is an official estimate, not a count.
• Non-EU groups: the threshold for the third-country reporting regime rose from EUR 150 million to EUR 450 million of EU turnover, with a EUR 200 million threshold for qualifying EU subsidiaries and branches.
• CSDDD: the due-diligence directive now targets EU companies with more than 5,000 employees and more than EUR 1.5 billion of worldwide turnover, with corresponding rules for non-EU companies. Transposition is due by 26 July 2028 and application starts on 26 July 2029.
• The specific CSDDD climate-transition-plan duty was repealed and the uniform EU civil-liability regime removed. National liability rules remain relevant.
• Revised reporting standards (ESRS) were adopted by the Commission on 3 July 2026 for financial years beginning in 2027. The Commission page we used said publication in the Official Journal was still pending, so check the current status.

What the value-chain cap protects, and what it does not

The reform gives suppliers with up to 1,000 employees a statutory right to refuse information requests that go beyond the voluntary standard for SMEs. It applies only when the request is made for CSRD reporting.

• It does not affect EU requirements for due-diligence processes.
• It does not affect information a customer asks for under a contract, a regulation or its own risk management.
• Under the CSDDD, a company may request information from business partners only where it is necessary, with additional proportionality limits for partners with fewer than 5,000 employees.

Why the questionnaires keep coming

Customers do not ask suppliers about ESG only because a law tells them to. They ask because of tenders that score suppliers, codes of conduct, customer audits and their own risk management. Assessment programmes show the scale: CDP reports that approximately 45,000 suppliers were requested to disclose through its supply chain programme in 2025, and EcoVadis tailors its questionnaire to the industry, size and country of each company and verifies the supporting documents.

Our reading is that the legal pressure changed shape while the commercial pressure stayed where it was: in contracts, tenders and customer programmes. A supplier that treats the Omnibus as the end of the questions risks being unprepared for the next one.

What to keep ready

1. Find out which questionnaire each customer actually uses, and whether the request is made for CSRD reporting or for another reason. The cap only helps in the first case.
2. Keep one set of evidence that answers most requests: policies, utility and fuel records, a greenhouse gas calculation, targets, training records and audit findings.
3. Record your answers once and reuse them, so each new request takes hours and not weeks.
4. Check how each of your customers’ countries is transposing the Omnibus, since national rules apply from 2027.

The free ESG Readiness Check shows how your company would fare in an ESG rating, and what a customer would find missing.