The Corporate Sustainability Reporting Directive (CSRD — EU 2022/2464) has been dramatically reshaped by the Omnibus I amending Directive — Directive (EU) 2026/470 — published in the Official Journal of the EU on 26 February 2026 and in force from 18 March 2026. The revised directive raises the CSRD mandatory scope to undertakings (or, for groups, parent undertakings on a consolidated basis) with more than 1,000 employees and net turnover exceeding €450 million — and it removes listed SMEs from the mandatory scope entirely. These thresholds apply from financial years starting on or after 1 January 2027 (first reports in 2028). Italy transposed the original CSRD via Legislative Decree 125/2024, now to be updated to reflect the revised European framework. If your company is still in mandatory scope — or receives CSRD data requests from customers further up the value chain — the Digital Product Passport becomes a primary data source for ESRS climate (E1) and circular economy (E5) disclosures.
What is this regulation?
CSRD requires large EU and EU-operating companies to publish audited sustainability information alongside their financial statements. The format is governed by the European Sustainability Reporting Standards (ESRS) and filed digitally (XBRL). Reporting is based on double materiality — considering both how the company impacts people and planet (impact materiality) and how sustainability issues impact the company financially (financial materiality).
Who must comply?
Under the Omnibus I amending Directive in force from 18 March 2026, mandatory CSRD reporting applies to undertakings — or, for groups, parent undertakings on a consolidated basis — that exceed both €450 million net turnover and an average of more than 1,000 employees during the financial year. Listed SMEs are removed from mandatory scope entirely. The revised thresholds apply for financial years starting on or after 1 January 2027 (first reports due in 2028). The scope change has been estimated to remove roughly 80% of companies originally captured by the directive.
How this impacts your business
Even if your company is now out of direct CSRD scope after Omnibus, you may still face supply-chain pressure: in-scope customers (Luxottica, Gucci, Ferrari, major European retailers) ask SME suppliers for ESRS-compatible data as part of their own reporting. The VSME voluntary standard is becoming the de-facto SME response framework. For Italian mid-caps that were scrambling for CSRD and are now out of scope, the opportunity is to redirect sustainability budget toward ESPR obligations you cannot escape — and use that work to answer customer value-chain questions cleanly.
How Deply helps
Deply Digital Product Passport captures product-level emissions, material composition, and supply-chain data that directly feeds ESRS E1 and E5 metrics — the hardest disclosures to produce without product-data infrastructure. For SMEs pressured by upstream customers, Deply exports VSME-ready data packages so you do not need to build separate ESG reporting systems. One platform, multiple regulations.
Frequently asked questions
Is my company still in scope for CSRD after the Omnibus?
Should we keep our double-materiality assessment if we are no longer required to report?
When exactly do the new thresholds apply?
Official sources
- Directive (EU) 2022/2464 — Corporate Sustainability Reporting Directive (CSRD)
- Directive (EU) 2026/470 — Omnibus I amending Directive
This page provides general information and does not constitute legal advice. Regulatory obligations depend on sector, product category, and jurisdiction.
Last updated: April 2026
