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CSRD 2026: Why the postponement is no reason to sound the all-clear
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Sustainability reporting in Europe has reached a new dimension. With the Corporate Sustainability Reporting Directive (CSRD), sustainability information is being elevated to the same level as financial figures – detailed, standardized, and externally audited. Thousands of companies were preparing for a profound transformation of their reporting processes. But at the end of 2025, the EU made a surprising turn: the so-called Omnibus Package brought far-reaching changes that disrupted the timetable for many companies.
The "stop the clock" rule postponed reporting requirements for the second and third waves by two years, and the thresholds for affected companies were raised dramatically. For many medium-sized companies, the danger seems to have been averted, and for large corporations, the pressure has been eased. But this first impression is deceptive. The CSRD is much more than a bureaucratic exercise. It is a strategic wake-up call that requires a profound re-examination of one's own business model. Those who misunderstand the postponement as an invitation to do nothing risk falling behind – not only in terms of regulation, but also in the competition for capital, talent, and customers.
The CSRD jungle: Why complexity remains despite the postponement
Although the adjustments made by the Omnibus Package have reduced the number of companies directly affected, the fundamental complexity of the requirements remains unchanged. The EuropeanSustainability Reporting Standards (ESRS) form a comprehensive framework that requires detailed and process-oriented reporting. The days of vague sustainability reports are finally over.
The CSRD replaces the previous Non-Financial Reporting Directive (NFRD) and goes far beyond a mere extension. While the NFRD only provided general guidelines, the CSRD, in conjunction with the ESRS, defines specific requirements for content, format, and auditing. For companies, this means a fundamental change: sustainability reporting will become an integral part of the financial and controlling process, and the requirements for data quality will correspond to those for financial reporting. Those who do not invest early on will not be able to meet the requirements.
The Omnibus Package: What has changed – and what has not
The latest adjustments have taken the immediate pressure off many companies, but the EU's fundamental thrust remains unchanged. The most important changes you need to know about are:
- New thresholds: The reporting requirement has been focused on companies with more than 1,000 employees and more than EUR 450 million in revenue. This relieves the burden on many medium-sized companies, but also means that the largest market players will be looking even more closely.
- "Stop the clock" rule: The reporting obligation for the second wave has been postponed by two years to the 2027 financial year. This time buffer is not a break, but a strategic preparation phase. The complexity of implementation remains, and the time needed to set up processes and systems is urgently needed.
While these changes reduce the number of those directly affected, they do not alter the depth of the requirements for those who remain within the scope. The need to establish audit-proof reporting remains.
The data challenge: The foundation for successful reporting
Regardless of deadlines and thresholds, one of the biggest hurdles to CSRD implementation remains data availability and quality. The information required for the ESRS is often scattered across different departments and IT systems – from human resources to production to purchasing. Many companies struggle with data silos, inconsistent formats, and a lack of processes for the systematic collection of ESG data.
The CSRD requires audit-proof data. Manual entries in Excel spreadsheets usually do not meet these requirements. The time buffer gained should therefore be used urgently to analyze your own IT landscape, identify data gaps, and develop a future-proof data strategy. Without a solid data foundation, compliant reporting is not possible. How you proceed in a structured manner is a key component of successful implementation.
The double materiality analysis: The heart of the CSRD
The core of the CSRD is the double materiality analysis. It determines which sustainability issues are relevant for a company and which ESRS standards must be reported on. Double materiality encompasses two perspectives:
- Impact materiality (inside-out): What actual or potential impact does the company have on the environment and society?
- Financial materiality (outside-in): What financial opportunities and risks arise from sustainability issues for the company itself?
Materiality analysis is not a one-time event, but a multi-stage, documented process. Those who fail to develop a robust methodology at an early stage will not be able to meet the requirements. Our white paper shows you step by step how to perform an audit-proof materiality analysis. The analysis is also a valuable strategic tool: it forces companies to identify their sustainability hotspots and address the opportunities and risks arising from the transition to a sustainable economy.
The strategic opportunity: Why it pays to get involved early
Even if your company is not directly subject to reporting requirements under the new thresholds for the time being, you will be indirectly confronted with the requirements of the CSRD. Large companies that continue to be subject to reporting requirements will demand the required sustainability information along their value chain. Banks and investors will increasingly weight ESG criteria in their lending and investment decisions.
Getting to grips with the CSRD at an early stage therefore offers decisive advantages:
- Competitive advantage: You position yourself as a sustainable and transparent partner for customers and suppliers.
- Risk management: You identify sustainability risks and opportunities at an early stage and can make your business model more resilient.
- Access to capital markets: You improve your attractiveness to investors and facilitate access to financing.
- Talent acquisition: A transparent sustainability strategy strengthens your employer brand.
Your way through the CSRD jungle: A practical guide
The CSRD is a complex but solvable task. The key to success lies in a structured approach and early preparation. To support you in this, our experts have created a comprehensive guide. Our new white paper, "CSRD Jungle Cleared: Your Practical Guide to Sustainability Reporting 2026," summarizes the current state of legislation (January 2026) and provides you with a concrete 5-step roadmap.
Learn how to:
Perform an audit-proof double materiality analysis.
Develop a robust data strategy and prepare your IT systems.
Implement the ESRS requirements step by step.
Use sustainability reporting as a strategic opportunity for your company.
Download our free white paper now and use the postponement to prepare yourself optimally for the new era of sustainability reporting!
If you want to take concrete action today, our ID-Report software will help you collect and evaluate your ESG data in a structured manner and report it in compliance with regulations.
FAQs on the CSRD
1. What are the most important changes brought about by the omnibus package?
The key changes are the increase in the thresholds to over 1,000 employees and €450 million in revenue, and the postponement of the reporting requirements for the second and third waves by two years.
2. What does "double materiality" mean in practice?
3. As a non-reporting company, am I affected by the CSRD?
4. What role does my IT play in CSRD implementation?
5. Should I start preparing now despite the postponement?
Contact our expert
This information only covers some of the challenges companies face on their path to greater sustainability. If you have any questions that aren't answered on our website, please contact us via email at sustain@abat.de. We will work with you to find solutions.