Omnibus Simplification of EU’s Sustainability Rules (CSRD and CSDDD) Enacted
Client Alert | March 4, 2026
The Amendment Directive which significantly narrows EU sustainability obligations for companies with respect to both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) has been officially published on February 26, 2026 and will enter into force on March 18, 2026. Here is what you need to know.
On February 26, 2026, the Amendment Directive (EU) 2026/470 significantly simplifying corporate sustainability reporting (CSRD) and corporate sustainability due diligence (CSDDD) requirements has been officially published and shall enter into force twenty days following publication on March 18, 2026. The final Omnibus agreement went much further in cutting sustainability reporting and due diligence obligations for companies than the package initially proposed by the European Commission in early 2025, see our client alert of February 28, 2025.
Now Member States are obliged to transpose these amendments into their national laws, namely regarding the Accounting Directive/CSRD by March 19, 2027 and regarding CSDDD by July 26, 2028.
Key Changes
The key changes in substance are summarized in our client alert of December 12, 2025.
Sustainability Reporting
EU subsidiaries of U.S. and other non-EU companies which are in scope, so-called “Wave 2 Companies”, will generally be due to report in 2028 for financial year 2027.
Companies already required to report under the CSRD for financial years starting in 2024 (“Wave 1 Companies”) but no longer meet the revised thresholds shall be out of scope for financial years 2025 and 2026, subject to national transposition.
The process of simplifying the applicable European Sustainability Reporting Standards (ESRS) is still ongoing, see our client alert of December 4, 2025. On December 3, 2025, the European Financial Reporting Advisory Group (EFRAG) released its draft simplified ESRS together with its final technical advice, and the European Commission currently reviews the draft and prepares its Delegated Act incorporating EFRAG’s technical advice. In the Amendment Directive, the European Commission committed to adopting the Delegated Act to revise the first set of ESRS within six months of the entry into force of the Amendment Directive on September 18, 2026. It is expected that the revised standards will start to apply for the reporting period of financial year 2027.
Sustainability Due Diligence
Compliance with CSDDD will be required for in-scope companies only by July 2029.
Gibson Dunn lawyers are available to assist in addressing any questions you may have about these issues. Please contact the Gibson Dunn lawyer with whom you usually work, any leader or member of the firm’s ESG: Risk, Litigation, and Reporting practice group, or the authors:
Ferdinand Fromholzer – Munich (+49 89 189 33-270, ffromholzer@gibsondunn.com)
Carla Baum – Munich (+49 89 189 33-263, cbaum@gibsondunn.com)
Vanessa Ludwig – Frankfurt (+49 69 247 411 531, vludwig@gibsondunn.com)
Johannes Reul – Munich (+49 89 189 33-272, jreul@gibsondunn.com)
Babette Milz – Munich (+49 89 189 33-283, bmilz@gibsondunn.com)
© 2026 Gibson, Dunn & Crutcher LLP. All rights reserved. For contact and other information, please visit us at www.gibsondunn.com.
Attorney Advertising: These materials were prepared for general informational purposes only based on information available at the time of publication and are not intended as, do not constitute, and should not be relied upon as, legal advice or a legal opinion on any specific facts or circumstances. Gibson Dunn (and its affiliates, attorneys, and employees) shall not have any liability in connection with any use of these materials. The sharing of these materials does not establish an attorney-client relationship with the recipient and should not be relied upon as an alternative for advice from qualified counsel. Please note that facts and circumstances may vary, and prior results do not guarantee a similar outcome.