Primarily large companies that fall under the CSRD are required to conduct sustainability reporting. For small and medium-sized enterprises, there is currently no direct reporting obligation under the Omnibus I package – yet, reporting is becoming increasingly important for them as well.
Specifically, following the adjustments within the Omnibus Initiative, only companies with more than 1,000 employees and over €450 million in revenue are subject to the binding CSRD reporting obligation. This removes approximately 80% of the originally expected reporting companies from the mandatory scope. At the same time, reporting obligations have been simplified: the focus is more on essential, quantitative information, and qualitative disclosure requirements have been significantly reduced. The amended directive is expected to be published in the Official Journal of the EU in March 2026 and will enter into force 20 days later.
In practice, however, the CSRD has an impact beyond the directly affected companies. Reporting companies must collect sustainability data along their value chains and rely on information from suppliers, service providers, and partners. This trickle-down effect means that even non-reporting companies are increasingly required to provide sustainability information.
Against this background, it can be beneficial for companies to address sustainability reporting early – even without a formal obligation. Structured, voluntary reporting creates transparency, reduces effort for recurring inquiries, and enables strategic management of sustainability instead of merely reacting to external requirements.
Thus, the role of reporting fundamentally changes: from a mere mandatory exercise to a voluntary but strategic instrument. A clearly defined sustainability strategy forms the basis for consistent content, while reporting is closely linked to ESG ratings, sustainable finance, and corporate decision-making. Companies that report transparently even without an obligation signal their ability to manage, credibility, and future orientation – and strengthen their market position.
