CSRD Revisions and Digital Reporting – update from the European Commission

Posted on May 29, 2026 by Editor

The European Commission's Omnibus I package, agreed by EU co-legislators on 9 December 2025, has substantially reshaped the scope and content of the Corporate Sustainability Reporting Directive. At yesterday's Digital Reporting Europe meeting in Paris, Ines Rohmer of DG FiSMA provided an excellent rundown on the changes. For those tracking the digital reporting implications, several developments are worth noting.

Under the revised regime, mandatory CSRD reporting applies only to companies with more than 1,000 employees and turnover above €450 million. This removes the mandatory obligation from approximately 85% of companies that were previously in scope, leaving around 6,500 companies subject to the requirements. The previous scope covered all large companies and all listed companies, including listed SMEs and non-EU companies listed in the EU.

For those 6,500 companies that remain in scope, the Commission has committed to revising and simplifying the European Sustainability Reporting Standards (ESRS) via a revised ESRS Delegated Act. EFRAG's technical advice projects a 34% cost reduction per reporting company, rising to 44% when value-chain cost reductions are included. The total number of datapoints is set to fall by 71%, with mandatory datapoints reduced by 61%, and all voluntary "may disclose" datapoints removed entirely.

A new protection potentially addresses the burden on smaller companies in supply chains. Companies with up to 1,000 employees now have an explicit right to decline requests for sustainability information that go beyond what the forthcoming voluntary standard requires. In-scope reporting companies are prohibited from contractually requiring such companies to provide information beyond that standard. Where a reporting company does seek additional information, it must identify precisely what falls outside the voluntary standard and remind the recipient of their right to refuse. After the existing three-year transition period, reporting companies must use directly collected data or estimates where value chain information remains unavailable.

On the digital infrastructure side, the Commission is required to provide a portal offering access to information, guidance and templates on the ESRS and the voluntary standard, and must publish a report within two years on technological solutions enabling data collection, processing and exchange in a "secure, seamless and automated manner."

The question of when a digital reporting mandate will apply to the remaining 6,500 in-scope companies has not yet been settled, but we expect that ESMA will initiate a consultation later this year.

The "stop-the-clock" postponement, enacted as Directive (EU) 2025/794, means large companies not previously subject to the NFRD (i.e: Wave 1 Filers) must report from financial year 2027, while listed SMEs-now largely out of scope-would have reported from FY 2028.

Find this very useful presentation, when available, on the event website here.