CSRD after Omnibus I: fewer companies subject to reporting requirements, with reporting to begin in 2028
- more than 1,000 employees (annual average)
- net turnover exceeding €450 million
The number of companies subject to the mandatory regime is therefore drastically reduced by around 80%.
The reporting obligation will come into effect from 2028, with reference to the 2027 financial year.
For companies with fewer than 250 employees, voluntary adoption of the VSME standard – Voluntary Standard for non-listed Small- and Medium-sized Enterprises – is recommended as a simplified and proportionate tool for addressing ESG disclosure requirements, particularly in the context of supply chain relationships with companies subject to the CSRD.
EUDR: the EU Deforestation Regulation and obligations from 2026
The European Union Deforestation Regulation (EUDR) was adopted to tackle the problem of deforestation and forest degradation linked to the production of certain raw materials: cocoa, coffee, soya, palm oil, cattle and natural rubber.
The regulation prohibits operators from placing these products on the European market unless they can provide guarantees regarding geolocation, land traceability and the submission of a due diligence statement (DDS).
Compliance with the EUDR is essential to ensure a zero-deforestation supply chain and to demonstrate environmental due diligence in imports into the European Union.
The provisions will come into force on 30 December 2026 for large operators and on 30 June 2027 for small operators.
PPWR: what changes for packaging, recyclability and labelling
The new European Packaging and Packaging Waste Regulation (PPWR), approved by the European Council in 2024 and which came into force on 11 February 2025, aims to reduce the environmental impact of packaging throughout the supply chain.
The regulation introduces mandatory standards for labelling, recyclability and proper disposal, making packaging design a regulatory tool to improve efficiency and recycling.
The first practical obligations will come into effect from 12 August 2026, according to a phased timetable.
EU Taxonomy 2026: simplifications and integration with the CSRD
The simplifications to the European Taxonomy aim to reduce implementation complexity, improve the comparability of ESG information and integrate the taxonomy into the financial statements required by the CSRD.
The regulation entered into force on 28 January, with retroactive application from 1 January 2026.