What changed in 2026
Directive (EU) 2026/470, known as the Omnibus I package, was published in the EU Official Journal on 26 February 2026. It amends the CSRD and sharply narrows the group of companies required to report. Member States have until 19 March 2027 to transpose the changes.
Delegated Regulation (EU) 2026/1560 sets out the voluntary sustainability reporting standard, known until now as the VSME. It was published on 21 September and has been in force since 24 September 2026. Any company without a reporting obligation can use it now.
Delegated Regulation (EU) 2026/1563 replaces the ESRS with a simplified version, with far fewer mandatory data points. It enters into force on 10 November 2026 and applies to large companies reporting for financial year 2027.
Who still has to report
At EU level, from financial year 2027, reporting applies to companies that exceed both thresholds: an average of 1,000 employees and €450 million in net turnover. The first reports under the new rules will appear in 2028. The report is checked by the auditor with limited assurance only. The stricter level of assurance originally planned has been dropped.
In Romania, the act in force is still Ministry of Finance Order 85/2024, which transposed the CSRD. On 7 September 2026 the Ministry of Finance put out for public consultation a draft order that adopts the new thresholds: more than RON 2.25 billion in net turnover and more than 1,000 employees. Under the draft, for financial years 2024–2026 only public-interest entities with more than 500 employees remain in scope. The exact obligations will be those in the final text of the order.
The Corporate Sustainability Due Diligence Directive (CS3D) has also been narrowed. It applies only to groups with more than 5,000 employees and €1.5 billion in turnover, and only from July 2029. For an SME, it creates no direct obligations.
| Date | What happens |
|---|---|
| 26 February 2026 | Directive (EU) 2026/470 (Omnibus I) is published in the Official Journal |
| 7 September 2026 | Romania's Ministry of Finance opens consultation on the draft transposing order |
| 24 September 2026 | The voluntary standard (Reg. 2026/1560) enters into force |
| 10 November 2026 | The revised ESRS (Reg. 2026/1563) enter into force |
| 1 January 2027 | The new CSRD thresholds and the value chain cap apply to financial year 2027 |
| 19 March 2027 | Deadline for transposing the CSRD changes into national law |
| 2028 | First CSRD reports under the new rules, for financial year 2027 |
| 26 July 2029 | CS3D starts to apply, to very large groups only |
Why customers ask you for data anyway
A large company that reports must also describe the impact of its supply chain, so it sends questionnaires to its suppliers. Banks ask for ESG indicators when granting loans, and some tenders and framework contracts include sustainability criteria.
Even when the law does not oblige you directly, a supplier that cannot answer consistently risks being seen as less reliable. Not because it does anything wrong, but because it cannot document what it does well.
The value chain cap: what can be asked of you and what you can refuse
From the financial year starting on 1 January 2027, a company reporting under the CSRD can no longer ask suppliers with 1,000 employees or fewer (average for the previous financial year) for information beyond the voluntary standard. In practice, the protection works like this:
- The customer can rely on your statement of your headcount, without further checks.
- If it asks for more than the standard provides, the customer must tell you.
- A contract clause requiring information beyond this level for CSRD reporting purposes is not binding on you.
The protection has a limit. The cap covers only requests made for CSRD reporting. Banks, customer auditors or other commercial or legal requirements can still ask for data on their own grounds. That is why a well-prepared VSME report serves you in both situations.
The voluntary standard, in plain terms for an SME
The standard is based on Commission Recommendation (EU) 2025/1710 and keeps two levels:
- the basic module, for companies just starting out;
- the comprehensive module, for companies facing more detailed requests from customers or banks.
The data required is usually data a company already has, just scattered: energy use and related emissions, water, waste and materials, workforce profile, health and safety, training, plus a few governance items. The voluntary report needs neither a double materiality assessment nor an external audit.
Lean, the engine that pays for ESG
Every ESG measure costs time and money. Lean removes waste from processes: unnecessary transport, idle inventory, scrap, waiting, extra motion and over-processing. Every waste removed shows up directly in the indicators you report:
- less scrap means fewer materials consumed and less waste;
- orderly flows cut machine idle hours, and with them energy use;
- organised workstations reduce the risk of accidents.
The savings fund the next steps. The report then stops being just a compliance document and shows real progress from one year to the next.
What to do now
- Ask your most important customers what data they will request for 2027 and in what format.
- Gather the data you already have for 2026: energy and fuel invoices, waste records, headcount, training, workplace incidents.
- Prepare the statement of your average headcount, to send to customers.
- Choose the right module, basic or comprehensive, based on what you are actually asked for.
- Identify one or two flows with visible waste. That is where you start with Lean.
How we work
- Diagnosis. We review the requests you receive from customers and banks and where you stand against the legal cap.
- Data. We structure the information you already have and fill the gaps, without costly systems.
- VSME report. We prepare the report in the right module, ready to send to customers.
- Lean. We map one or two process flows and remove losses of time, materials and motion.
- Action plan. We set realistic priorities for an SME's resources, with indicators tracked every year.
Quotes are tailored, after the initial diagnosis.
Who it is for: manufacturers, industrial suppliers and distributors that receive sustainability questionnaires from large customers, and companies that want to cut operational waste before investing in ESG measures.
See also: Why your large customers ask you for sustainability data.
Receiving sustainability questionnaires from customers? Let's see what can actually be asked of you.
Frequently asked questions
Does my company have to publish a sustainability report?
If you do not exceed both 1,000 employees and €450 million in turnover, you have no such obligation under the new EU rules. In Romania, until the transposing order is adopted, check your position under Order 85/2024 and the Ministry of Finance draft.
What is the VSME?
It is the European voluntary sustainability reporting standard, designed for companies without a CSRD obligation. Since 24 September 2026 it has legal form, through Delegated Regulation (EU) 2026/1560.
Can I refuse a large customer's questionnaire?
From financial year 2027, you can refuse information beyond the voluntary standard if you have 1,000 employees or fewer and the request is made for the customer's CSRD reporting. You can provide the data in the standard anyway, and a complete answer strengthens your position as a supplier.
Does the protection apply to banks too?
Not directly. The cap covers only requests made for CSRD reporting. Banks can ask for data under their own lending rules, but a VSME report usually covers much of it.
What data do I need to gather?
Energy and fuel use, waste, water, workforce data, health and safety, training and a few governance items. Most of it already exists in invoices and internal records.
How long does it take to prepare a VSME report?
It depends on how orderly your data is and on the module chosen. That is why we start with a diagnosis, before any estimate.
Why do you combine ESG with Lean?
Because the efficiency gained with Lean cuts costs and, at the same time, improves the reported indicators: energy, materials, waste, accidents. ESG measures can then be funded from the savings.
What about the CS3D, the due diligence directive?
It applies only to very large groups, with more than 5,000 employees, and only from 2029. An SME may at most receive indirect requirements, through contracts with these customers.
Official sources
- Directive (EU) 2026/470 (Omnibus I), on EUR-Lex
- Delegated Regulation (EU) 2026/1560, voluntary standard, on EUR-Lex
- Delegated Regulation (EU) 2026/1563, revised ESRS, on EUR-Lex
- Commission Recommendation (EU) 2025/1710, on EUR-Lex
- Directive (EU) 2022/2464 (CSRD), on EUR-Lex
- Ministry of Finance Order 85/2024 (Romanian), on legislatie.just.ro
- Romanian Ministry of Finance draft order of 7 September 2026, Transparency section of mfinante.gov.ro
- All relevant acts, with official links: Legislation page