FREN

Should you still publish a CSR report if you fall outside the CSRD?

The Omnibus I directive has sharply reduced the number of companies subject to sustainability reporting. Many companies that were preparing their first CSRD report are no longer required to publish one. So the question arises: should you carry on?

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What changed in 2026

EU Directive 2026/470 was published in the Official Journal of the European Union on 26 February 2026.1 It limits the obligation to companies with more than 1,000 employees and net turnover above €450 million.2 The ESRS standards have been streamlined, and the revised version applies to financial years starting on or after 1 January 2027.

Why publish anyway

  • Large buyers remain subject to the CSRD and ask their suppliers for information.
  • Banks and investors build ESG criteria into their decisions.
  • Candidates look at what employers commit to.
  • The data work already under way keeps its value.

The voluntary framework: the VSME standard

On 30 July 2025 the European Commission recommended the VSME standard, designed by EFRAG for small and medium-sized enterprises.3 It has a basic module and a comprehensive module. It gives you a common language with customers and funders.

A shorter, more readable report

Stepping outside the obligation also frees up the format. A voluntary report can focus on the issues that really matter to the company and its audiences. It gains in readability what it gives up in exhaustiveness.

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