Sustainability Reporting After the Omnibus: Who Still Has to Report, and When

Our own archive has a piece from early 2024 predicting a wave of roughly 50,000 European companies gearing up to write their first sustainability report under the Corporate Sustainability Reporting Directive. That number was correct at the time. It is no longer the number, and if you're scoping a reporting project against it, you're scoping against a directive that has since been rewritten twice over.

What the Omnibus actually did

In February 2025 the European Commission proposed the "Omnibus" package, aimed at cutting the compliance burden the CSRD and its sister rules had created. The headline change is what's known as "stop-the-clock": the second and third waves of companies due to report — large non-listed companies and listed SMEs — had their reporting obligations deferred by two years. A company that expected to publish its first CSRD report in 2026, covering financial year 2025, is now expected to publish in 2028, covering FY2027 (Dcycle's timeline breakdown is a clear reference if you need the exact wave dates for a client).

The scope change is the bigger story for anyone writing about this. Listed SMEs, originally due to join under Wave 3, are largely being lifted out of mandatory CSRD reporting altogether, with policy pushing them instead towards a simplified, voluntary framework based on the VSME standard. Put the two changes together and the population of companies with a live mandatory reporting obligation has fallen from an estimated 50,000 to something closer to 5,000 — a roughly 90% reduction (Coolset's scope analysis walks through the maths).

Who is actually reporting in 2026

The companies still filing this year are, broadly, the ones that were already reporting under the old Non-Financial Reporting Directive before the CSRD replaced it: large listed companies and large financial institutions above the revised thresholds of roughly 1,000 employees and €450 million turnover. These are the organisations publishing FY2025 reports now, under the existing standards, while everyone in the deferred waves gets a two-year reprieve.

There's a second moving part worth flagging to a client before you scope a project: the Commission is working on a simplified set of European Sustainability Reporting Standards (ESRS), with the revised delegated act expected before the end of 2026 and the simplified standards due to apply from FY2027. Companies will be able to apply them voluntarily a year early, for FY2026. So a report written this year could reasonably be built to either the current ESRS or a simplified draft version, depending on how far along the client's own reporting maturity already is — worth confirming before the brief is locked, not after the first draft.

The Swiss position runs on its own clock

For anyone writing for a Swiss-headquartered company, the CSRD itself doesn't apply directly — Switzerland isn't an EU member state. What applies is the domestic non-financial reporting regime under articles 964a–c of the Swiss Code of Obligations, which was revised specifically to track the CSRD rather than copy it wholesale, with the updated rules and the revised Climate Reporting Ordinance in force from 1 January 2026 (MLL's summary of the revision has the detail). Reporting produced to meet the CSRD is generally expected to satisfy the Swiss requirement too, which matters for any Swiss company that reports into an EU parent, or any EU subsidiary reporting up into a Swiss group. From 2026 the climate report itself also needs to exist in both a human-readable format and a machine-readable one, after a transition year — worth checking with the client's finance team before the content brief is finalised, because that's a production requirement, not a writing one, and it changes the file you're eventually handed.

What this changes about the brief

Three practical differences from the 2023–24 version of this conversation:

• The reader has changed. A report written for a company newly caught by mandatory disclosure reads differently from one written for a large-cap that has been doing this since the NFRD days. Fewer first-timers means less need to explain the basics from scratch, and more room to write for a reader who already knows the acronyms.
• Voluntary reporting is now its own category, with its own tone. A mid-sized company choosing the simplified VSME route isn't complying with a mandate — it's making a reputational choice, and the copy should read like one. That's a different brief from a compliance document, closer to the kind of purpose-led writing we've covered elsewhere in the archive.
• Don't assume the scope you scoped last year still applies. If a client briefed a report in 2024 anticipating a 2026 filing under Wave 2 or 3, that filing has almost certainly moved to 2028. Confirm the wave and the applicable standard before quoting the job, not after.

If you're scoping a report right now

The practical fix is to ask the client which wave they actually sit in before agreeing a delivery date, rather than assuming last year's timetable still holds. A company that briefed a 2026 report under the old Wave 2 schedule may now not need a mandatory filing until 2028 — which either frees up the budget for something else this year, or gives everyone two extra years to build a genuinely good report instead of a rushed first attempt. Neither is a bad outcome, but both require the wave to be confirmed, in writing, before the brief is priced.

None of this changes the underlying discipline of writing a sustainability report well — the substance still has to be accurate, the claims still have to be traceable to the client's own data, and the design and structure principles we've covered before still hold. What's changed is who's asking, and when the deadline actually falls. Get that wrong and the rest of the brief doesn't matter.