The Omnibus I directive, published in the EU Official Journal on 26 February 2026, brought a wave of relief to many finance departments. The thresholds for entering CSRD scope have been raised (1,000 employees and €450 million in net revenue, cumulative), and a share of companies that had spent two years preparing for a first sustainability report are now exempt. The relief is real. For many, it's also incomplete.
Two waves, one text
Large listed public-interest entities with more than 500 employees ("wave 1", inherited from the former NFRD) remain subject to their original timeline, already underway since fiscal year 2024, independent of the Omnibus threshold increase. "Wave 2", the one Omnibus pushed back to the new thresholds, will publish its first ESRS report in 2028, covering fiscal year 2027. In between, a large number of companies that expected to come into scope soon now find themselves effectively outside the mandatory scope, at least for now.
The exemption that isn't quite one
This is where the story doesn't stop at the letter of the law. A company outside CSRD scope that sells to a large group subject to the directive will keep receiving ESG data requests, because its client has to document its own value chain to produce its report. The legal obligation changed thresholds; the commercial demand hasn't gone away.
Two mechanisms structure this residual demand. The voluntary VSME standard (Voluntary SME standard) is becoming the common reference large groups point their non-CSRD suppliers to: a recognized format, simpler than the full ESRS, but a real data-collection format nonetheless. The "value chain cap" caps what a company subject to CSRD can demand from its non-subject suppliers: protection against over-solicitation, not a removal of the demand itself.
What this means for an "exempt" SME
Knowing you're outside the mandatory scope is still good news, but it's not the same as never having to produce ESG data again. Companies that treat this exemption as a permanently closed topic risk discovering the VSME request the moment a strategic client raises it, rather than anticipating it. Those that keep their supplier reference data and environmental data structured (even without a direct legal obligation) approach that request as a formality rather than an emergency project.
Source: Directive (EU) 2026/470 (Omnibus I), EU OJ 26/02/2026; French transposition by 19/03/2027 at the latest; French Commercial Code, art. L.820-1 and art. L.821-6