Your SME is no longer subject to mandatory CSRD reporting – what now?
The Omnibus I package removed approximately 80% of companies from the scope of mandatory CSRD reporting. If your company falls below the new thresholds – more than 1,000 employees and more than €450M in turnover – the mandatory obligation no longer applies. However, this does not mean that sustainability work or stakeholder interest will disappear. This article outlines the available options, what expectations still apply to your company, and how to move forward sensibly.
What is Omnibus? Read more about it here: CSRD and Omnibus – what changed and what it means for companies in 2026
The first question: should we stop reporting altogether?
The answer is almost always no – at least not entirely.
Even if the law no longer requires publishing a report, there is demand for sustainability data from many directions.
- Financiers and banks need sustainability data to meet their own reporting obligations (SFDR, EU Taxonomy).
- Customers – especially large companies still subject to CSRD – collect data from their value chains for their own reporting.
- Investors conduct ESG assessments of smaller or unlisted companies as well.
- Recruitment and employer image: younger employees in particular value sustainability when choosing an employer.
The change brought by Omnibus is therefore primarily an administrative relief, not a reason to discontinue sustainability work.
Three options for SME sustainability reporting
Option 1: The VSME Standard
VSME (Voluntary Sustainability Reporting Standard for SMEs) is the EU’s recommended reporting standard for all companies not subject to CSRD obligations. It is considerably lighter than CSRD but covers the same themes and is structurally aligned with it.
VSME consists of two modules:
- The Basic module focuses on key numerical indicators such as emissions, energy consumption, and headcount figures. It is a good starting point for companies beginning their sustainability reporting.
- The Comprehensive module adds a strategic perspective and includes a broader set of indicators. It better meets the information needs of large customers.
VSME is particularly well suited for a company that has not previously reported on sustainability, whose customers are subject to CSRD and collect data from their own value chains, or that wants to apply a clear and widely recognised reporting approach without the heavy workload of CSRD.
Omnibus limits the right of large companies to request data from their partners. Companies with fewer than 1,000 employees may refuse data requests that go beyond the scope of VSME. Adopting VSME therefore also provides a clear basis for responding to such requests.
Read more about VSME
Option 2: Voluntary CSRD Reporting
If a company has already invested in CSRD preparation – conducted a double materiality assessment, collected data, and built processes – it may make sense to continue on the same path voluntarily.
However, voluntary CSRD reporting requires that the report fully complies with the European Sustainability Reporting Standards (ESRS) as the CSRD directive demands, and that the report is assured in the same way as mandatory reporting.
Voluntary CSRD is particularly suitable for a company whose headcount and turnover are approaching the reporting thresholds, or whose customers or financiers expect CSRD-level reporting and transparency. It may also be the case that if preparation is already well advanced, stepping back does not feel like a sensible choice.
Option 3: GRI Reporting
If a company already has experience with GRI reporting (Global Reporting Initiative), continuing with it is a fully justified choice. GRI is the most widely recognised sustainability reporting standard internationally and has significant overlaps with CSRD.
GRI is especially suitable if the company’s customers or investors are familiar with and value GRI reporting. Globally, GRI is better known than EU-specific standards. By continuing GRI-based reporting, the company does not need to adopt a new framework.
GRI is not the EU’s official recommendation as a replacement for CSRD, but many financiers and customer companies accept it fully.
What to do in practice – next steps
Regardless of the chosen option, the following actions are worth taking:
- Check stakeholder expectations. Which of your customers are subject to CSRD? What are banks or financiers asking? What data is required in tenders? The answers will indicate how comprehensive your reporting needs to be.
- Don’t discard work already done. Your CSRD preparation may have already produced a double materiality assessment, data collection processes, and other documentation. These should be leveraged in sustainability work and reporting rather than starting from scratch.
- Choose your reporting framework. Decide on the reporting standard you will apply and communicate this to your stakeholders. Ambiguity is a worse option than simpler but consistent reporting.
- Prioritise material topics. With Omnibus, the role of materiality assessment remains very significant, even in voluntary reporting. You do not need to report on everything possible – only on those matters that are genuinely important to the business and its stakeholders.
- Keep structures in order. Data collection, tracking of indicators, and integrating sustainability into business operations are worth continuing even if reporting becomes lighter. They benefit the company itself, and when the next regulatory change arrives or the company grows, you will already be prepared.
Regulation does not end with Omnibus
Omnibus significantly eases reporting obligations, but it does not end regulation. The directive states that the Commission must assess by 2031 whether the scope should be broadened again. In addition, many countries, financial institutions, and international actors are developing their own requirements.
Companies that keep their sustainability structures in good order now will be better positioned when the next change arrives – whether it is a new obligation, a customer data request, or a financing negotiation.
