CSRD after the Omnibus: leaving the scope does not exempt from measuring

Adopted by the European Parliament in December 2025, published in the Official Journal on 26 February 2026 and in force since 18 March, the Omnibus package delivered its simplification promise: a company now falls under the CSRD only if it exceeds both 1,000 employees and 450 million euros in revenue. According to the Commission, around 80% of initially targeted companies leave the scope.

The standards themselves have just been lightened: on 3 July 2026 the Commission adopted the delegated act carrying the revised ESRS, cutting mandatory datapoints by more than 60% (more than 70% in total) and reporting costs by at least 30% per company, applying to financial years starting on or after 1 January 2027. For thousands of mid-caps that were preparing for reporting, the temptation is huge: stop everything.

That would misread the movement. The very large companies still in scope must document their value chain, and that requirement trickles down: their suppliers, out of the regulatory scope, remain in the commercial scope. The buyer's ESG questionnaire replaces the directive, with one notable difference: it does not warn, it conditions the contract.

Add banks and insurers, folding sustainability into their terms, and public tenders, which score it. The legal obligation has concentrated; the de facto requirement has spread.

The Omnibus does not stop at reporting: it also lightens the due diligence directive (CS3D), tightening its scope and calendar. But the underlying logic survives the simplification: the very largest players remain responsible for their value chain, and will therefore keep questioning their suppliers, scope or no scope.

For companies out of the field, EFRAG is in fact pushing a dedicated voluntary standard, designed as a common language between SMEs and buyers. The signal is limpid: mandatory reporting recedes, standardised sustainability data becomes the lingua franca of commercial relations.

On the ground, procurement departments of in-scope groups are rationalising their supplier questionnaires around the simplified standards, banks are folding sustainability into their credit grids, and public procurement scores it in tenders. Three channels, one consequence: the average mid-cap will answer dozens of ESG solicitations a year.

Without an internal measurement base, every questionnaire becomes a project: re-collect, re-estimate, send figures that diverge from one client to the next. The hidden cost of “no more obligation” can exceed the obligation's cost, if the data was never structured once and for all.

The rational position for a mid-cap is neither the pre-Omnibus reporting factory nor abandonment: it is a measured, proportionate ESG maturity, from which you can extract on demand whatever a client, a bank or a public tender requires. Knowing where you stand on energy, emissions, supply chain, without mobilising a full-time team.

That is exactly what a maturity framework enables: structured measurement first, reporting as a by-product, in the requested format. The Omnibus removed the obligation to tell everything; it did not remove the need to know.