{"id":1086,"date":"2026-10-08T12:00:00","date_gmt":"2026-10-08T10:00:00","guid":{"rendered":"https:\/\/www.controlaudit.es\/?p=1086"},"modified":"2026-10-14T09:39:59","modified_gmt":"2026-10-14T07:39:59","slug":"omnibus-directive-csrd-companies-in-scope","status":"publish","type":"post","link":"https:\/\/www.controlaudit.es\/en\/blog\/omnibus-directive-csrd-companies-in-scope\/","title":{"rendered":"Omnibus I Directive: which companies will have to report on sustainability, and from when"},"content":{"rendered":"
In brief<\/b>Directive (EU) 2026\/470 (Omnibus I) limits the EU sustainability reporting obligation to companies with net turnover above \u20ac450,000,000 and an average of more than 1,000 employees, for financial years beginning on or after 01\/01\/2027. It has not been transposed in Spain: the bill transposing the CSRD lapsed on 06\/10\/2026 when the Cortes Generales (Spanish Parliament) were dissolved. The non-financial information statement (EINF) under Law 11\/2018 remains in force and applies to companies with more than 250 employees that meet certain conditions.<\/div>\n

Legislative status as at 08\/10\/2026:<\/strong> Directive 2026\/470 is in force in the EU but has not been transposed in Spain. The Bill on corporate sustainability reporting (121\/000038) was never passed: following Royal Decree 806\/2026 of 5 October dissolving the Cortes Generales and calling elections (BOE of 06\/10\/2026), the Congress record shows it as \u00abConcluido – (Caducado)\u00bb (concluded, lapsed) from 06\/10\/2026. Transposition will require a new legislative initiative in the new parliamentary term, with no foreseeable date, and the EU deadline expires on 19\/03\/2027. We will update this article when the situation changes.<\/p>\n

Will your company have to prepare a sustainability report under the EU Corporate Sustainability Reporting Directive (CSRD)? After Omnibus I, for the vast majority the answer is no. We explain what has changed, from when, and what remains in force in Spain. If your company is not in scope but your customers are asking for environmental or social data, you may also be interested in our guide on the sustainability data a customer may ask you for and the voluntary VSME standard<\/a>.<\/p>\n

What has changed with Omnibus I<\/h2>\n

Directive (EU) 2026\/470 of the European Parliament and of the Council of 24\/02\/2026 was published in the Official Journal of the European Union on 26\/02\/2026. It amends, among others, Accounting Directive 2013\/34\/EU, Directive 2022\/2464 (CSRD) and Directive 2024\/1760 on corporate sustainability due diligence (CSDDD). According to the Spanish Institute of Accounting and Auditing (ICAC), it entered into force on 18\/03\/2026.<\/p>\n

Its main effect is a drastic reduction in the number of companies in scope. The original CSRD covered all large undertakings under the size criteria of the Accounting Directive and listed SMEs. Omnibus I replaces that scope with two thresholds that must both be met and removes listed SMEs.<\/p>\n

Before that, Directive (EU) 2025\/794 of 14\/04\/2025, known as stop-the-clock<\/em>, had already been adopted. According to the ICAC, it postponed application by two years for large undertakings that were not yet reporting (the so-called second wave) and for listed SMEs.<\/p>\n

New thresholds: \u20ac450m and 1,000 employees<\/h2>\n

The new art. 19a of Directive 2013\/34\/EU requires sustainability information to be included in the management report by undertakings that, on their balance sheet date, have generated net turnover above \u20ac450,000,000 and<\/strong> exceed an average of 1,000 employees during the financial year. The same rule applies to groups on a consolidated basis (art. 29a). The balance sheet total criterion disappears.<\/p>\n

The conjunction is worth stressing: exceeding just one of the two thresholds is not enough. A company with 1,200 employees and net turnover of \u20ac300,000,000 is out of scope, as is another with \u20ac600,000,000 and 800 employees.<\/p>\n\n\n\n\n\n\n\n\n\n
Aspect<\/th>\nBefore Omnibus I<\/th>\nAfter Omnibus I<\/th>\nPosition in Spain as at 08\/10\/2026<\/th>\n<\/tr>\n<\/thead>\n
Who reports<\/td>\nLarge undertakings under the Accounting Directive and listed SMEs<\/td>\nNet turnover above \u20ac450,000,000 and more than 1,000 employees<\/td>\nCSRD not transposed; the EINF under Law 11\/2018 applies<\/td>\n<\/tr>\n
Balance sheet criterion<\/td>\nYes, as one of the size criteria<\/td>\nRemoved<\/td>\nThe EINF still uses total assets and turnover<\/td>\n<\/tr>\n
Listed SMEs<\/td>\nIncluded (application postponed)<\/td>\nExcluded<\/td>\nNo specific obligation<\/td>\n<\/tr>\n
First financial year of the new scope<\/td>\n\u2014<\/td>\nFinancial years beginning on or after 01\/01\/2027<\/td>\nAwaiting a Spanish law<\/td>\n<\/tr>\n
Transposition<\/td>\n\u2014<\/td>\nBy 19\/03\/2027 (reporting provisions)<\/td>\nPending: Bill 121\/000038 lapsed on 06\/10\/2026 without being passed<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Incorrect figures in circulation<\/h3>\n

Some industry publications still quote thresholds of 500 employees or turnover of \u20ac250,000,000, which do not match the adopted text. The figures in the Official Journal, also reported by the ICAC, are \u20ac450,000,000 and 1,000 employees.<\/p>\n

Timetable: entry into force, transposition and first financial years<\/h2>\n