"Omnibus I" Reforms Take Effect - Reporting Scope Dramatically Narrowed

The CSRD scope now only covers EU companies with more than 1,000 employees and €450 million revenue (up from prior thresholds), while Wave I companies (large listed entities, banks, insurers with 500+ employees) continue in-scope until end of 2026 but member states may now disapply the rules for 2025 and 2026 to smaller Wave I filers. For CS3D, only companies with more than 5,000 employees and €1.5 billion worldwide revenue are in-scope.

Enforcement timeline: Member states have 12 months to transpose CSRD changes into national law and until July 2028 for CS3D changes.

For company secretaries: Companies previously in scope must now reassess their reporting obligations. Value chain partners below reporting thresholds can now decline information requests that would exceed voluntary SME reporting standards, capping administrative cascades.