What happened
The Omnibus I Directive (2026/470), which simplifies the EU's sustainability reporting and due diligence rules, was published in the Official Journal of the EU on 26 February 2026 and entered into force on 18 March 2026. The directive concludes the simplification process the Commission launched in February 2025.
Main changes:
- CSRD scope: The reporting obligation now covers only companies with an average of more than 1,000 employees and net turnover above EUR 450 million.
- Non-EU parent companies: Non-EU ultimate parent companies are in scope if they generated more than EUR 450 million net turnover in the EU in each of the last two financial years and have an EU subsidiary or branch with turnover above EUR 200 million. For these companies, reporting starts with financial years beginning in 2028.
- Timeline: For EU companies, the scope applies from financial years beginning in 2027. Member states may exempt first-wave companies from reporting for 2025 and 2026. The deadline for transposing the CSRD amendments into national law is 19 March 2027.
- Value chain cap: Companies reporting under the CSRD cannot request information beyond the voluntary SME standard (VSME) from value chain companies with an average of fewer than 1,000 employees.
- CSDDD: The due diligence threshold has been raised to more than 5,000 employees and EUR 1.5 billion net turnover; for non-EU companies, EUR 1.5 billion turnover in the EU is the benchmark. The obligation to adopt a climate transition plan has been removed. The compliance date is July 2029.
Who is affected
Turkish companies are affected in two ways. First, Turkish groups with large turnover and subsidiaries in the EU should recalculate their scope under the non-EU parent company rule. Second, there is a supply chain effect: for Turkish suppliers with an average of fewer than 1,000 employees, the information EU customers can request for CSRD purposes is capped at VSME level. However, this cap applies only to information requests made for CSRD reporting; data requests for SBTi targets, the EU Carbon Border Adjustment Mechanism (CBAM) or other commercial purposes fall outside it.
What companies should do
- Compare the turnover of your EU subsidiaries with the new thresholds.
- Compare questionnaires from your EU customers with the VSME scope and clarify which data is requested for which purpose.
- Keep your inventory up to date, since product- and company-level emissions data requests continue despite the simplification.
Alalëa supports companies in preparing Scope 1, 2 and 3 inventories that can answer customer data requests: carbon footprint.
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