You were preparing your first sustainability report for 2026, you had hired a CSR lead, built a double materiality assessment, and started on scope 3. Then the Omnibus arrived. The "simplification" directive put forward by the Commission in early 2025 redrawn the CSRD's scope with sweeping threshold changes: roughly 80% of companies originally covered now fall outside its mandatory perimeter[1]. That is the crux of the CSRD Omnibus mid-market question: it is no longer "how do we comply?" but the more unsettling "are you even in scope?" And if the answer is no, what do you do with everything you had already put in place?
- After the Omnibus, the CSRD only applies to companies that exceed both 1,000 employees and €450M net revenue, cumulative thresholds that take the vast majority of mid-market companies out of mandatory scope[2].
- The "Stop-the-Clock" directive (EU 2025/794) also pushes back the entry of subsequent waves by two years: wave 2 now only reports on the 2027 financial year[3].
- Exiting the regulatory perimeter does not mean escaping ESG data pressure: customers, banks, and investors continue to request ESG data, which is why a voluntary framework like the VSME makes sense.
CSRD Omnibus: the new thresholds reshaping the scope
Before the Omnibus, the CSRD was set to cover roughly 55,000 European companies under a "two out of three criteria" test. The simplification package replaced that mechanism with a stricter one: to fall within the CSRD's scope, a company must now simultaneously exceed 1,000 employees and €450M consolidated net revenue[2]. The knock-on effect: the perimeter drops to around 11,000 companies across the EU. Roughly 80% of those originally targeted are out[1].
| Criterion | Before Omnibus | After Omnibus |
|---|---|---|
| Headcount | > 250 employees | > 1,000 employees |
| Net revenue | > €50M | > €450M |
| Logic | 2 out of 3 criteria | Cumulative (both required) |
| Companies in scope (EU) | ~55,000 | ~11,000 |
In France, this means a mid-market company with 600 employees and €120M revenue (typically one that was about to produce its first report in 2027) is no longer subject to the obligation. Listed SMEs are largely removed from scope too. What remains is a core group of large companies that keep their obligations, sometimes with lighter content requirements.
Stop-the-Clock: two years' breathing room, then what?
The timeline shifted with the "Stop-the-Clock" directive (EU 2025/794), which delays entry into force by two years for wave 2 and wave 3 companies[3]. In practice, a company that was supposed to report on the 2025 financial year will not do so until the 2027 financial year (published in 2028), if it exceeds the new thresholds. For many, that "if" becomes a definitive "no".
On content, the Omnibus also provides for a scaled-back revision of the ESRS standards (fewer indicators) and removes certain obligations, such as the climate transition plan as a standalone section. The message is clear: lighten the load. But lighter is not gone, and companies remaining in scope will find their reporting subject has shifted, not disappeared.
"I'm no longer required to" — yet the pressure remains
That is the Omnibus trap: exiting the regulatory perimeter does not switch off ESG data demand. Three forces continue to push mid-market companies toward transparency, even without a formal obligation.
1. The value chain. ESRS standards require large companies to incorporate their value chain into their reporting: suppliers, subcontractors, distributors[4]. A large customer consolidating its scope 3 will come knocking for your emissions data. Failing to provide it risks getting dropped from their supplier list, or showing up as "missing data" in their report. The constraint flows through the contract, not the law.
2. Lenders and investors. Banks and funds are increasingly weighting extra-financial performance when setting lending terms and cost of capital. Bpifrance makes the point clearly: ESG criteria, anchored to the EU green taxonomy, carry real weight in financing decisions[5]. A mid-market company that cannot produce a carbon assessment or a materiality analysis walks into its bank empty-handed, a genuine disadvantage when competitors have already structured their approach.
3. Tenders and reputation. Public procurement and large corporate buyers now routinely ask for standardised CSR information in their RFP questionnaires. Having structured reporting, even voluntary, speeds up responses and strengthens bids. Conversely, an absence of data has become a de facto elimination criterion.
Mandatory CSRD is retreating. Demand for CSR data is not. A mid-market company out of scope is not exempt from transparency — it simply shifts from a regulatory framework to a contractual and financial one.
The VSME: a voluntary framework built for mid-market and SMEs
Rather than scrapping everything or, alternatively, continuing to single-handedly comply with ESRS standards that are too burdensome, there is a third way: the VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs), published by EFRAG in December 2024[6]. It is a streamlined version of the CSRD, designed for companies not subject to the directive that want, or need, to structure their reporting.
The VSME is organised into two levels: a basic module (a minimal data set, accessible to smaller organisations) and a comprehensive module for those that need to meet more demanding requests from their value chain. The benefit: a common language, recognised by customers and lenders, that replaces a patchwork of disparate questionnaires. For more detail, our dedicated page on the VSME as a voluntary standard covers the modules and implementation.
The impact angle: why voluntary beats inaction
Beyond compliance, there is a more compelling reason not to pull the plug entirely: real impact. A structured CSR approach (measuring emissions, planning reductions, being transparent on governance) drives better decisions for the company and for the climate, regardless of any obligation. That is exactly the logic behind Greenway's 1%ForAll® programme: 1% of every transaction is donated to the Greenway Foundation in a measurable, auditable way, rather than as an abstract pledge.
Voluntary commitment also has a strategic advantage that regulation never offers: you choose it. You decide on the depth, the pace, the scope. You align the approach with your business rather than with a regulatory grid. Companies that had committed early to the CSRD often experienced it that way, less a constraint than a management lever. The Omnibus does not make that investment obsolete; it makes it optional, and therefore freer.
What to do in practice, depending on your situation
Three scenarios, three courses of action.
You exceed the thresholds (1,000+ employees and €450M+). You remain in scope. Use the Stop-the-Clock breathing room to strengthen your data quality and prepare for the lighter ESRS revision. Do not relax: the timeline has moved; the obligation has not.
You were in scope and are now out. This is the most common situation. Do not dismantle everything. Keep what you have built (data collection, emissions mapping) and migrate it onto a voluntary framework, typically the VSME. That is what will let you respond quickly to customer and lender requests without starting from scratch.
You were never in scope. Now is the time to build a baseline that fits your size: a first carbon assessment, a basic VSME module, a responsible procurement policy. The entry cost is low; the returns (market access, financing, reputation) are real.
Frequently asked questions
Does the CSRD still apply to my mid-market company after the Omnibus?
Only if you simultaneously exceed 1,000 employees and €450M consolidated net revenue. These cumulative thresholds remove roughly 80% of originally targeted companies from mandatory scope[1][2].
What is the "Stop-the-Clock" directive?
It is EU directive 2025/794, which delays the entry into force of the CSRD by two years for wave 2 and wave 3 companies. Wave 2 now reports on the 2027 financial year instead of 2025[3], provided the new thresholds are met.
My company is no longer obligated: do I still need to do CSR?
Pressure now comes from the value chain (ESG data requests from large customers), lenders (ESG criteria for credit), and tender processes. A voluntary framework like the VSME lets you structure this approach without the full weight of the ESRS[6].
What is the VSME?
The VSME (Voluntary Sustainability Reporting Standard for SMEs) is a voluntary standard published by EFRAG in December 2024, designed for SMEs and mid-market companies not subject to the CSRD. It offers a basic module and a comprehensive module, both lighter than the ESRS[6].
My CSRD-obligated customers are asking for my data: what should I say?
Responding with structured reporting built on the VSME framework lets you handle disparate questionnaires in one go and builds credibility with your customers. The ESRS requires large companies to integrate their value chain, so these requests are not going away[4].
Is the 1%ForAll® programme connected to the CSRD?
Not directly: it is a voluntary impact mechanism (1% of every transaction donated and traced), not a regulatory requirement. It embodies the opposite logic of the CSRD, chosen commitment rather than imposed compliance, while generating measurable data that feeds into a broader CSR approach.
Pillar guide: this article is part of our CSR & CSRD white paper, which connects regulatory obligations, voluntary commitment, and measurable impact.
References
- DAF Mag, How to prepare for ESG reporting obligations after the Omnibus directive (approx. 80% of companies exit mandatory scope; ~55,000 → ~11,000 in the EU). daf-mag.fr. ↩
- economie.gouv.fr, Everything you need to know about the CSRD. Applicable thresholds after the Omnibus: more than 1,000 employees and net revenue above €450M. economie.gouv.fr. ↩
- Accountancy Europe, Omnibus CSRD provisions. "Stop-the-Clock" directive (EU 2025/794): two-year delay for waves 2 and 3. accountancyeurope.eu. ↩
- Plana, Mastering value chain communication for the CSRD. Integration of suppliers and subcontractors in ESRS reporting. plana.earth. ↩
- Bpifrance, ESG criteria: definition, examples, and challenges for companies. The weight of ESG criteria and the EU green taxonomy in financing decisions. bigmedia.bpifrance.fr. ↩
- Portail RSE (beta.gouv.fr), VSME: understanding voluntary standards for SMEs. EFRAG standard published in December 2024. portail-rse.beta.gouv.fr. ↩
