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CSRD after the Omnibus – what companies need to know now

CSRD after the Omnibus: thresholds rise, first filings for new entrants shift to 2028 (FY2027). What stays: double materiality, assurance, audit-ready data.
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Last updated
October 15, 2025

Europe’s reporting landscape is shifting, but the direction of travel is set. The Omnibus process aims to simplify the Corporate Sustainability Reporting Directive (CSRD) without dismantling its core: decision-grade, auditable data that links environmental and social impacts to enterprise value. For many mid-sized and fast-growing companies, the big questions are scope, timing, and how to use the extra time wisely. In a recent LinkedIn Live hosted by Sweep, policy expert Julien Denormandie and climate-finance advisor David Carlin unpacked what the latest changes mean and how leaders can turn compliance into capability.

What changed post-Omnibus – and what didn’t

After the Legal Affairs Committee (JURI) vote, the package moves to plenary and then trilogue, where Parliament, Council, and Commission will settle the final text. While details can still evolve, the likely contours are clear.

1. Thresholds: companies are expected to be in scope if they have at least 1,000 employees and €450 million in EU turnover. 

2. Timing: newly in-scope companies will report in 2028 on financial year 2027. 

3. Indicators: the ESRS datapoints look set to slim from roughly 1,150 to around 350–450, pending EFRAG’s proposal and Commission adoption.

Equally important are the elements that won’t move. Auditability remains non-negotiable: data must be traceable and capable of limited assurance (moving higher over time). Double materiality remains central. And extraterritorial reach is still an EU priority; foreign groups with substantial EU activity should expect to be covered, with thresholds finalised later.

You will see significant changes on timing, scope and the number of indicators. But auditability and double materiality remain, and the EU still wants extraterritorial reach. Use the new thresholds and dates to plan – don’t wait for the last minute.

Julien Denormandie
CIO, Sweep

Why acting early creates advantage

The Omnibus is not an excuse to pause; it’s a gift of time to build durable capabilities. Waiting until 2027 risks a scramble, higher costs, and thin strategic value. Focus on three pillars now.

Data: map sources, standardise definitions, and close gaps across subsidiaries and suppliers. Treat Scope 3 as an information architecture challenge, not just a calculation.

Systems: define ownership, workflows and escalation paths. Connect sustainability with finance, risk and audit so disclosure mirrors how the business operates; reporting should be the output of real management processes, not a year-end paper chase.

Skills: upskill executives and teams in double materiality and IRO (impacts, risks, opportunities), climate scenarios, transition planning, and key social/nature topics. Know what matters for your model and where decisions need to change.

Capital markets are already pricing this in. Investors increasingly treat decision-grade sustainability information as the price of admission. Opacity invites a discount; clarity is often rewarded.

This isn’t a ‘wait until 2027’ moment. Build the data, systems and skills you’ll need anyway – and make reporting the output of strategy, not a year-end exercise. In capital markets, clarity gets rewarded; opacity gets discounted.

David Carlin
Climate finance expert

Technology and AI: accelerate, but keep it auditable

Technology can materially reduce complexity – there is just no magic button. Use software and AI to speed up slow steps while preserving provenance and human oversight so everything remains auditable.

Collect data at scale with consistent definitions, use version control, approvals and audit logs, and deploy AI to propose first drafts for qualitative disclosures from source documents. AI can help detect anomalies and support supplier engagement with guided forms. None of this replaces internal governance: escalation paths, ownership, and evidence trails are as important as data pipelines. Many organisations will sensibly track additional KPIs not explicitly required by ESRS (e.g., data security) so dashboards reflect the real cockpit used by management and investors.

Julien reframed a common worry: CSRD is not so much complex as comprehensive. With a leaner indicator set, the right platform, clear roles, and selective AI assistance can turn comprehensiveness into usable, assured information.

AI can pre-populate qualitative answers and streamline workflows – but every field must remain auditable: sources, who submitted, who reviewed, what changed. There is no magic button. The goal is to make a comprehensive regulation manageable and valuable.

Julien Denormandie
CIO, Sweep

What it means for leaders now

Asked what newer filers can learn from early reporters, Julien pointed to the IRO lens as the biggest value driver. Companies that treat CSRD as more than a checkbox – using impacts, risks and opportunities to steer strategy – gain wider internal engagement and clearer investment priorities. Moving from spreadsheet sprawl to structured workflows brings finance, procurement and risk into one governance loop. The payoff is not just a cleaner report; it’s higher-quality data, better decisions and an audit trail that holds up.

Done well, CSRD becomes a strategic capability: earlier visibility of risks and opportunities, stronger access to capital, and a sharper story to stakeholders about how your business will compete – and thrive – in a changing economy.

Sweep can help

Sweep is a carbon and ESG management platform that empowers businesses to meet their sustainability goals.

Using our platform, you can:

  • Conduct a thorough assessment of your carbon footprint.
  • Get a real-time overview of your supply chain and ensure that your suppliers meet your sustainability targets.
  • Reach full compliance with the CSRD and other key ESG legislation in a matter of weeks.
  • Ensure your sustainability information is reliable by having it verified by a third party before going public.
See how we can help you on your sustainability journey