On 18 March 2026, Directive (EU) 2026/470, commonly known as Omnibus I, officially entered into force.
This text significantly amends two major directives:
- the CSRD (Corporate Sustainability Reporting Directive)
- the CSDDD (Corporate Sustainability Due Diligence Directive)
The result? Rules of the game that change entirely — and many SMEs that do not yet know what this means concretely for them.
In this article, we will explain clearly:
- what Omnibus I changes compared to the previous situation
- who is still affected
- and what French SMEs must do right now
Already receiving ESG questionnaires from your clients or bank? Read our article first: ESG Questionnaires: Why SMEs Can No Longer Keep Up
Why was Omnibus I adopted?
Since 2023, the CSRD has required large companies to publish detailed reports on their environmental, social and governance impact.
The problem?
The regulation was considered too burdensome, too complex, too costly — particularly for mid-sized companies.
According to the European Commission, the initial framework would have affected more than 50,000 companies in Europe, with compliance costs estimated between €150,000 and €400,000 per entity for the first year.
Faced with these criticisms, the Commission decided to simplify. Omnibus I is the response to this demand.
What changes concretely
-
Far fewer companies directly within CSRD scope
Definition: CSRD scope The “CSRD scope” refers to all companies that have a legal obligation to publish a sustainability report according to ESRS standards. Only these companies are directly subject to the CSRD.
Before Omnibus I, companies exceeding 250 employees or €40 million in turnover were progressively included in scope.
After Omnibus I, the threshold was significantly raised.
Only companies with:
- more than 1,000 employees
- AND more than €450 million in turnover
are now directly affected.
Result: approximately 80 to 90% of initially targeted companies exit mandatory scope.
-
Timelines have been postponed for subsequent waves
“Wave 2” and “Wave 3” companies benefit from a two-year delay.
Listed SMEs, formerly “Wave 4”, have been removed from mandatory CSRD scope.
Member States have 12 months to transpose the directive into national law. France must therefore legislate before March 2027
-
Double materiality remains mandatory
Definition: Double materiality Double materiality consists of analysing two directions: Financial materiality: how ESG risks affect the company’s performance (an “outside-in” view). Impact materiality: how the company’s activities affect society and the environment (an “inside-out” view). Both dimensions remain mandatory for all companies within CSRD scope, even after Omnibus I.
This is a point many leaders overlook.
The simplification does not affect the principles — it affects scope and certain required data points.
-
Reasonable assurance is postponed to 2028 at the earliest
Today, companies in scope have their sustainability report verified under limited assurance only.
The move to reasonable assurance, a more demanding level, has been postponed to at least 2028 under Omnibus I.
But are SMEs really off the hook?
No.
And that is the most frequent mistake.
Even if your SME exits direct CSRD scope, you will continue to receive ESG requests. Why?
Because large companies subject to the CSRD must analyse their value chain and therefore question their suppliers, subcontractors and partners.
Definition: Value chain The value chain refers to all actors involved in creating a product or service: raw material suppliers, subcontractors, logistics providers, distributors. Under the CSRD, large companies must collect ESG data from these actors, even when they are not themselves subject to the directive.
Concretely: you are not subject to the CSRD, but you are in the value chain of a company that is.
That is precisely why the VSME remains a strategic tool for French SMEs, even after Omnibus I.
Also read: VSME: The Simplified ESG Standard for SMEs
What French SMEs must do now
Step 1: Check your actual situation
Ask yourself two concrete questions:
- Does my company have more than 1,000 employees?
- Does my turnover exceed €450 million?
If yes to both: you remain directly within CSRD scope. Act without delay.
If no to either: you exit direct scope. Move to step 2.
Step 2: Identify your clients and partners in scope
Do you have clients or buyers who are within CSRD scope?
If yes, these clients will send you ESG data requests in the coming months. Anticipate them with a structured approach.
Step 3: Don’t pause your ESG approach
This is the temptation of many leaders after Omnibus I.
“We’re out of scope, we can wait.”
Strategic mistake.
European banks are progressively integrating climate criteria into their financing decisions (ECB, 2024). Major buyers apply ESG criteria in their tenders. Conditions for access to finance and markets do not wait for regulatory timelines.
An SME that structures itself now will be more competitive in 2027.
Step 4: Follow French transposition
Omnibus I entered into force at European level.
France has until March 2027 to transpose the directive into national law. Adjustments specific to the French context are possible.
Stay informed of developments via publications from the CNCC (Compagnie Nationale des Commissaires aux Comptes) and the AMF (Autorité des Marchés Financiers).
In summary
| What Omnibus I changes | What Omnibus I does not change |
| Application thresholds raised (1,000 employees / €450M turnover) | Double materiality remains mandatory |
| Waves 2 and 3 postponed by 2 years | ESG requests across the value chain continue |
| Listed SMEs removed from scope | ESG criteria from banks and clients persist |
| Reasonable assurance postponed to 2028 | Limited assurance remains required for companies in scope |
FAQ: Omnibus I and French SMEs
Does Omnibus I abolish the CSRD? No. Omnibus I simplifies and reduces CSRD scope — it does not abolish it. Large companies (more than 1,000 employees and €450M turnover) remain fully subject to the directive.
My SME is outside CSRD scope after Omnibus I. Do I still need to produce an ESG report? Not necessarily. But if you are a supplier to a large company subject to the CSRD, you will probably receive ESG questionnaires from them. The VSME is a voluntary and proportionate option for responding effectively.
When will France transpose Omnibus I into national law? Member States have 12 months from 18 March 2026 to transpose the directive. France must therefore legislate before March 2027.
Is double materiality still mandatory after Omnibus I? Yes. Double materiality remains the founding principle of the CSRD. Omnibus I expressly maintained it, while simplifying certain data points required in the ESRS.
Need help navigating these changes?
Many French SMEs find themselves in an uncomfortable position:
- they had started an ESG approach in anticipation of the CSRD
- Omnibus I changes the rules
- and now they no longer know what to prioritise
At Eco Fluent Solutions, we help SMEs to:
- analyse their actual positioning against the new rules
- structure their ESG approach in a proportionate way
- respond effectively to ESG questionnaires from their value chain
Book a call to review your situation.
Eco Fluent Solutions is a consultancy specialising in ISO management systems and sustainability governance. We support SMEs in turning ISO and ESG requirements into operational systems, without over-documentation or unnecessary complexity.
SME support: discover how to structure your responses to ESG and VSME questionnaires.
