After the Omnibus Earthquake: Time for Strategic Clarity for European Companies

The approval of the Omnibus directive clarifies CSRD thresholds and timelines. ESG reporting is entering a more stable phase, yet remains a strategic priority in light of funder requirements and international competition.

Solène Garcin-Charcosset
Directrice Conseil ESG et Carbone
Publication : 
23.02.2026
Table of Contents
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🔎 Key takeaways

  • The approval of the Omnibus directive puts an end to regulatory uncertainty: the new CSRD thresholds and timelines are set, ushering in a period of stabilization in 2026.
  • ESG reporting is shifting toward “structured voluntary reporting”, with pressure now coming from commercial and financial stakeholders (banks, insurers, clients), particularly through the VSME standard.
  • Data quality and standardization remain essential for sustainable finance, helping to prevent greenwashing and maintain access to funding, especially for SMEs and mid-caps.
  • Against a backdrop of international competition (notably from China), ESG transparency is becoming a strategic competitive advantage for European companies.
  • 2025 will be remembered as a year of great uncertainty for Europe's sustainability strategy. Between calls for simplification and geopolitical tensions, the Green Deal faced an unprecedented period of turbulence. Yet, with the final approval of the Omnibus directive last December, the fog is finally beginning to lift. For business leaders, the question for 2026 is no longer whether the transition will happen, but how to steer it pragmatically within this new, stabilizing framework.

    A political rift that served as a warning

    The legislative journey of the Omnibus directive revealed a fragility that few had anticipated in Brussels. The circumstantial alliance between the European People's Party (EPP) and the far right to dismantle the pillars of the CSRD and the duty of vigilance served as a wake-up call.

    This breach of the political “cordon sanitaire” poses a major risk for companies. This episode serves as a reminder that environmental regulation has become an ideological battleground, opening the door to numerous challenges on other issues (nine further omnibus proposals are set to follow this first one). However, the text has now been approved and will be voted on during the first quarter of 2026. For senior management, this final step is a victory: the end of uncertainty. The framework is now set, the thresholds are known, and the timelines are fixed.

    Moving beyond “reporting for reporting's sake”

    The raising of the CSRD thresholds has drastically reduced the number of companies directly subject to the requirement, but it does not signal a disengagement by companies. Europe argues that by concentrating efforts on the most structurally important players, the effectiveness of the measures will be similar, at a much lower cost and with far greater competitiveness.

    For companies that fall outside the legal scope, the pressure does not disappear; it changes in nature. It becomes commercial and financial. Banks, insurers and major clients continue to demand sustainability data to assess their own risks. The difference is that in 2026, we are entering the era of structured voluntary reporting (in particular via the VSME standard for SMEs and mid-caps). The objective is clear: turn an administrative burden into a lever for competitive differentiation.

    Sustainable finance in the fog

    The financial sector, a driving force behind green reindustrialisation, risks finding itself left without support. The promise of the CSRD and the Taxonomy was simple: to provide reliable, comparable and auditable data to direct capital towards the most resilient business models.

    The current unravelling could penalise the best performers. Without standardised data, the risk of voluntary or involuntary “greenwashing” increases, and with it, investor caution. In the end, it is SMEs and mid-caps that could pay the price, through more complex or more costly access to credit. The risk is of creating a two-speed Europe, where the companies that form the backbone of our real economy find themselves excluded from international value chains simply for lack of transparency.

    Facing the “Chinese model”, the advantage of transparency

    Meanwhile, while Europe was debating its thresholds, China was advancing its own pieces. By openly drawing on European standards for its own non-financial reporting rules, the CSDS, Beijing has confirmed an intuition: ESG data is the new language of global value. The irony is stark: Europe invented the software of the transition, but it is China that is installing it.

    Despite the criticism, the CSRD remains the most robust tool for identifying companies that are resilient to climate and social shocks. By stabilising this framework, the EU is giving its companies a comparative advantage: that of auditable transparency, a guarantee of trust for international investors who are increasingly fleeing opacity.

    2026: The year of implementation

    The time of “back-room dithering” is behind us. Companies now have a roadmap that, while trimmed back, remains ambitious. For finance and CSR departments, it is now time for operational integration.

    The simplification achieved through the Omnibus directive should be seized for what it is: an opportunity to focus on genuine materiality. Fewer indicators, more focus on major transformations to the business model. The uncertainty has been lifted; it is now up to business leaders to turn this regulatory clarity into a growth engine.