CSRD After Omnibus: Why Exempt SMEs Are Still Being Asked
Omnibus took the vast majority of companies out of mandatory sustainability reporting. It did not remove the demand. It moved it to the buyers.
Since the Omnibus directive came into force in March 2026, I have been hearing two opposite stories from the owners of small and mid-sized businesses. The first: “It's over, we're out of scope, we can file the whole thing away.” The second, rarer but more accurate: “We're out of the obligation, not out of the demand.”
The second is right, and here is why.
What Omnibus actually changed
The mechanism is easy to summarise. The criteria that bring a company within the CSRD have moved from alternative thresholds to cumulative thresholds, and they have been raised.
Before: 250 employees or 50 million euros of turnover or 25 million euros of balance sheet total. After: 1,000 employees and 450 million euros of turnover — both conditions having to be met at the same time.
The effect is enormous. The number of companies directly subject to sustainability reporting across the Union falls from roughly 50,000 to an order of magnitude of 10,000. Listed SMEs, originally in the frame for 2027, are out of mandatory reporting altogether.
The timetable has slipped too: the second wave of reporting companies will report in 2028 on financial year 2027 data, following national transposition expected in 2027. And the ESRS standards themselves have been significantly lightened, with the number of data points cut by something of the order of 60%.
On paper, that is a considerable relief for the European economy. In practice, for an SME supplying a large customer, almost nothing changes.
The trickle-down effect has not been repealed
Here is the three-step reasoning to keep in mind.
One. Large companies still in scope have to document their scope 3 — the indirect emissions generated across their value chain.
Two. A large customer's scope 3 is its suppliers' scopes 1 and 2. Mathematically, it cannot produce its report without obtaining data from its suppliers, exempt or not.
Three. That data ends up inside the scoring grids used by procurement departments. Not out of activism, but because the buyer has an obligation of his own to satisfy. And a criterion that enters a purchasing grid sooner or later becomes a knock-out criterion.
That is what I see on the ground, including in my own sectors: healthcare, cosmetics, specialist retail. The ESG questionnaires keep arriving, and a regulatory exemption is not an acceptable answer in a tender.
VSME: the good news nobody has read
The most useful item in this file is also the one least known to SME owners. A proportionate standard has been designed for companies outside the scope: the VSME (Voluntary Sustainability Reporting Standard for SMEs), whose adoption by delegated act was expected during the summer of 2026.
Two features genuinely matter.
It is far lighter: of the order of a hundred data points, against several hundred for the full ESRS, and with no audit requirement.
It works as a ceiling. This is the decisive point: a company subject to the CSRD is in principle not entitled to require of a supplier with fewer than 1,000 employees any information going beyond the VSME standard. Translated into commercial negotiating language: faced with an eighty-page ESG questionnaire sent by a large group, an SME can legitimately answer with a VSME report and point to that ceiling.
You have to know it exists, of course. I see a great many SMEs labouring through disproportionate requests simply because nobody has told them about this framework.
What I advise an SME owner to do today
Doing nothing is not an option, and doing too much is not one either. The right posture sits between the two, and it is essentially a commercial one.
Step one: measure once, properly. An emissions assessment covering scopes 1 and 2, and a first pass at scope 3. That is the foundation of every answer you will give afterwards. The budget orders of magnitude observed for an SME sit, in the first year, in a range of a few tens of thousands of euros all in, with public support schemes covering a significant part of the carbon measurement — Bpifrance's Diag Décarbon'Action is the best-known example in France. Check the conditions currently in force before committing the spend.
Step two: write it up in VSME format. A single document, kept up to date annually, that answers eighty per cent of the questionnaires you receive. That turns a repeated, imposed chore into a reusable commercial asset.
Step three: make it an argument, not a burden. This is where most owners miss the point. An SME that holds reliable data before its competitors do is not suffering the constraint: it is turning it round. In a tender where three suppliers out of four answer “we don't have those figures”, the one who provides them gains an advantage that has nothing to do with price.
One conviction, to finish
I spent nine years running a natural cosmetics SME, and since 2024 I have sat on the board of COSMEBIO, the French federation for organic and ecological cosmetics. That taught me one thing: sustainability badly understood is a cost; sustainability well understood is a management discipline.
Measuring what you consume, knowing your tier-two suppliers, knowing where your raw material comes from, anticipating the future price of energy and carbon — these are the reflexes of a good manager before they are regulatory requirements. The companies that had adopted them before the CSRD did not have to reorganise when it arrived. And they will not have to reorganise when the cursor moves again — because it will move again.
Omnibus has not closed the subject. It has bought time. That is a very different thing.
Main source: Projet Celsius — CSRD 2026 : qui est encore concerné après l’Omnibus ?. Thresholds, timetables and support schemes are moving quickly, so check the state of the applicable law before taking any decision.
