“Omnibus” has become the word that worries SME owners and executives whenever sustainability comes up. Behind the term lies a package of European measures that, in early 2026, redrew the scope of reporting obligations and the room left for voluntary reporting. The most frequent question remains the same: when does it apply in France? Here is the state of the law on 8 November 2026, fact by fact, without anticipating anything that has not yet been adopted.
Omnibus I: which directive are we talking about exactly?
The “Omnibus” simplification package gave rise to two texts that must be carefully distinguished, as they are often confused.
The first, the so-called “stop-the-clock” directive – Directive (EU) 2025/794, adopted on 14 April 2025 – merely postponed the reporting deadlines while the substantive reform was being negotiated. It is a timing directive, not a substantive one.
The second, the true “substantive” Omnibus I directive, is Directive (EU) 2026/470 of 24 February 2026. Published in the Official Journal of the European Union on 26 February 2026, it entered into force on 18 March 2026 (CELEX reference 32026L0470). It is this text that actually amends the scope of the CSRD and introduces the mechanism capping the requests made to smaller businesses.
The new scope of the CSRD: two cumulative thresholds
The change with the greatest consequences concerns which companies fall within the scope of the CSRD. Following Omnibus I, a company falls within the mandatory scope only if it exceeds two cumulative thresholds:
- more than 1,000 employees;
- and more than €450 million in net turnover.
The logic is indeed that of an “and”: both conditions must be met. This is not a “two out of three criteria” rule of the kind found elsewhere in accounting law. This wording raises the bar very significantly: according to estimates put forward at the time of adoption, it would take some 80% of companies out of the mandatory scope of the CSRD.
This is precisely where VSME/VS comes into its own. The companies leaving the mandatory scope do not, however, vanish from the ESG radar of their customers and banks; they then turn to voluntary, standardised reporting. To understand what this framework is, see our in-depth page on the VSME/VS standard and its two modules.
The value chain cap: what a client company can still ask for
The other major contribution of Omnibus I is the value chain cap. The idea: a large company subject to the CSRD cannot require its partners with 1,000 employees or fewer to provide more information than the voluntary standard contains.
In practice, an SME faced with an oversized ESG questionnaire could invoke this cap and decline requests that exceed it; contractual clauses imposing more would be null and void. An exception is, however, provided for information commonly shared within the same sector (the exact wording will appear in the published text). This mechanism is anchored in Directive 2013/34/EU (Articles 19a and 29a, according to proposal COM(2025) 81) and only becomes fully operational after transposition into national law.
For an SME supplier, it is a practical tool for protection in dealings with client companies. We explain how it works, and how to respond to a customer questionnaire, in our feature on VSME/VS and the value chain.
The delegated act of 3 July 2026: the voluntary standard has been in force since 24 September 2026
The final piece of the puzzle, and the most recent: the voluntary standard (VS). Following a public consultation held from 6 May to 3 June 2026, the European Commission adopted, on 3 July 2026, a delegated act (reference C(2026) 5011) establishing this standard.
After being transmitted to the European Parliament and the Council for a review period (scrutiny), this delegated act was published in the Official Journal of the EU on 21 September 2026 as Delegated Regulation (EU) 2026/1560; it has been in force since 24 September 2026. Care is needed, however, not to jump ahead: the value chain cap it sets only applies to financial years beginning on or after 1 January 2027. The abbreviation “VS” is not defined in the enacting terms of the delegated act – the texts refer to a “voluntary reporting standard” – but it is now used by EFRAG, by the ANC (French accounting standards authority) and by the Portail RSE (French government CSR portal) of the Ministry of the Economy.
This voluntary standard builds on VSME/VS, the standard developed by EFRAG and submitted to the Commission on 17 December 2024, already endorsed on an interim basis by Recommendation (EU) 2025/1710 of 30 July 2025 – a non-binding soft law instrument. VSME/VS and VS are therefore two related but distinct items, at different stages of legal development.
Two dates that should not be confused. The standard becomes usable as soon as it enters into force, that is, on the third day following its publication in the Official Journal of the European Union (Article 4). The value chain cap, by contrast, only applies to financial years beginning on or after 1 January 2027 (Article 3). In other words, nothing prevents an SME from applying the standard before 2027.
So when does it apply in France?
That is the real question. Here are the timing milestones on which there is currently a consensus:
- New CSRD thresholds: they apply to financial years beginning on or after 1 January 2027, with first reports published in 2028.
- Transposition into French law: Member States must transpose the CSRD part of Omnibus I by 19 March 2027 at the latest (the due diligence part, CSDDD, follows its own timetable, until 26 July 2028).
- Value chain cap: it becomes fully operational once this transposition has taken place.
- Voluntary standard (VS): in force since 24 September 2026 (Delegated Regulation (EU) 2026/1560); its value chain cap applies to financial years beginning on or after 1 January 2027.
In other words, for a French SME, nothing is triggered automatically in 2026. The issue is gaining momentum mainly through commercial channels: customer requests, loan applications, calls for tender. It is this pressure “from further down the chain” that makes VSME/VS a useful tool well before any regulatory deadline.
Where does the text stand? Published in the Official Journal of the EU on 21 September 2026 (Delegated Regulation (EU) 2026/1560), it has been in force since 24 September 2026; each step (transmission to the Council, right of objection, publication) is dated on our regulatory watch.
What this means in practice for your business
Key takeaways: the CSRD is refocusing on very large companies; the vast majority of SMEs and mid-sized companies fall outside it; and so that they are not left empty-handed when faced with their partners’ ESG questionnaires, these companies now have a voluntary framework designed for them, bounded by the value chain cap. To find out whether you yourself are in scope or not, our page on the VSME/VS standard sets out the various scenarios.
Because this framework continues to evolve – publication of the VS in the Official Journal is the next step to watch – we maintain a dated and sourced regulatory updates page. To follow each text as it develops, see our VSME/VS and VS news and regulatory updates, updated with every development.
Sources and verification — checked on 8 November 2026
Every regulatory statement on this page has been checked against the official text. The references below allow you to verify them for yourself.
- Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026 (adopted under reference C(2026) 5011), “supplementing Directive 2013/34/EU of the European Parliament and of the Council by establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap” — legal basis: Article 29ca(1) of Directive 2013/34/EU. Published in the Official Journal of the EU (L series) on 21 September 2026, in force since 24 September 2026 (Article 4); its Article 3 (value chain cap) applies to financial years beginning on or after 1 January 2027. Official text on EUR-Lex · version adopted on 3 July 2026 (PDF, European Commission). Relevant provisions: Articles 1 (definition of the cap), 2(1) (who may apply the standard), 3(2) (the cap covers only the data points in Annex II), 4 (entry into force), recital 5 (end of the legal effects of the Recommendation, message to lenders and investors). Transmitted to the European Parliament and the Council on 3 July 2026 (Council document 11697/26 of 9 July 2026).
- Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 (adopted under reference C(2026) 5010, revision of the ESRS): reduces the number of mandatory data points by 61%. Published in the Official Journal of the EU on 21 September 2026; enters into force on 10 November 2026 (Article 3) and applies to financial years beginning on or after 1 January 2027. Official text on EUR-Lex · adopted version (PDF, European Commission).
- Recommendation (EU) 2025/1710 of 30 July 2025 (endorsement of EFRAG’s VSME), OJEU of 5 August 2025 — text on EUR-Lex. Recital 5 of Delegated Regulation (EU) 2026/1560 provides that it “should be considered as no longer producing legal effects” from the entry into force of that regulation, i.e. from 24 September 2026.
- Directive (EU) 2026/470 of 24 February 2026 (Omnibus I), published in the OJEU on 26 February 2026, entered into force on 18 March 2026 — text on EUR-Lex. National transposition due by 19 March 2027 at the latest.
- EFRAG — VSME/VS digital template and XBRL taxonomy, version 2.0.0 of 4 November 2026 (prepared in accordance with the voluntary standard (VS), Delegated Regulation (EU) 2026/1560 published in the Official Journal of the EU on 21 September 2026; it replaces version 1.3.0 of 11 June 2026, which EFRAG says should no longer be used) — EFRAG page.
A question about the timeline? We track the status of each text, with dates, in our regulatory watch.
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