Two delegated acts were adopted on 3 July 2026. The one that gets the attention from smaller companies is the value chain cap. The other one matters at least as much, because it decides how many companies are still asking.
What was adopted
The Commission adopted the final delegated act containing the simplified European Sustainability Reporting Standards, referred to as ESRS (2026). It is based on technical advice EFRAG submitted on 3 December 2025, which proposed cutting the number of mandatory datapoints by 61 percent. Both acts are subject to a scrutiny period of two months for the European Parliament and the Council, extendable by a further two.
Who still has to report
The Omnibus I Directive, Directive (EU) 2026/470, adopted on 24 February 2026 and in force since 18 March, narrowed the scope of mandatory sustainability reporting to undertakings that exceed both thresholds on their balance sheet date: a net turnover above 450 million euro and an average of 1000 employees during the financial year.
Both, not either. A 1200-person company with 300 million euro of turnover is out. So is a 400-person company turning over 600 million.
When it applies
ESRS (2026) applies for financial years beginning on or after 1 January 2027. For financial years beginning during 2026 there is a transitional choice: a company can apply the 2023 standards, the 2026 standards, or the 2023 standards with specific options taken from the 2026 set.
What this means if you supply those companies
Three practical consequences, in the order you will notice them.
- Fewer questionnaires. Customers that dropped out of scope have no reporting obligation to pass down. Some will keep asking out of habit or because a procurement policy says so, but they are no longer asking because the law makes them.
- Shorter questionnaires from the rest. A customer working from a set of standards with 61 percent fewer mandatory datapoints has less to collect from you.
- A cap on top of both. Whatever remains, the value chain cap limits it to the voluntary standard for any supplier with no more than 1000 employees.
The thing not to conclude
None of this means the questions stop. It means they get smaller and more predictable, which is a different and better problem. Banks still ask, insurers still ask, tender documents still ask, and none of those are governed by the CSRD scope thresholds. The reason to have a report is no longer that a directive compels your customer to demand one. It is that answering the same eleven disclosures once beats answering seven different questionnaires every spring.
Joost Thissen
