Here's a number that should be reshaping conversations in boardrooms right now, and largely isn't: industry estimates suggest 85 to 90% fewer companies now fall under mandatory EU sustainability reporting than did a year ago.
The Omnibus simplification cut deep. CSRD now only applies to companies above 1,000 employees and €450 million in net turnover. CSDDD's threshold jumped to 5,000 employees and €1.5 billion. A huge number of companies that spent 2024 and 2025 preparing for mandatory reporting are now outside the perimeter.
If that's you, the instinct is relief. I'd pause before taking it.
Three things happened in July that most companies haven't clocked yet.
First: the Commission adopted the revised European Sustainability Reporting Standards on July 3, cutting mandatory data points by more than 60%. That's now official, not proposed.
Second, and this is the one worth your attention: EFRAG released a draft standard specifically for non-EU companies, ESRS-40a, that applies when a non-EU parent company meets certain group-level thresholds, regardless of where its subsidiaries report. The consultation is open until October 31.
If your company has a European subsidiary and a parent headquartered outside the EU, this standard is being built right now to potentially apply to you at the group level, separate from whether your EU entity individually crosses the CSRD threshold.
Third: this isn't a US-only conversation. The UK's own carbon border mechanism takes effect January 1, 2027, a parallel track most companies focused on Brussels haven't started tracking.
Here's the pattern worth naming.
The Omnibus didn't remove regulatory attention from mid-sized and non-EU companies. It restructured where that attention lands, moving from broad, direct disclosure requirements toward narrower, sharper mechanisms: border carbon pricing, group-level standards for non-EU parents, buyer-driven data requests replacing government-mandated ones.
Smaller in scope. Not smaller in consequence for the companies still caught inside it.
The companies navigating this well right now are the ones reading the specific mechanism that applies to their actual structure, not assuming that "narrower CSRD" means "off the hook."
Every professional in this space is navigating something different. This short survey helps me understand exactly where you are, so the signals, context, and opportunities I share actually match what matters to you right now.
If you're trying to work out whether ESRS-40a, CBAM, or the narrowed CSRD actually applies to your structure - reply directly. I'll help you think it through honestly.
— André
Sources: KPMG, "Sustainability reporting in the EU," August 2026 · Reporting Academy, "EU Sustainability Regulation in 2026," August 2026 · Latham & Watkins, "EU Sustainability: State of Play," 2026