What the Omnibus changes
The CSRD Omnibus — formally Directive (EU) 2026/470 — was published in the Official Journal of the European Union on 26 February 2026 and entered into force on 19 March 2026. It amends the original CSRD (Directive 2022/2464/EU) and introduces three significant changes to mandatory sustainability reporting scope:
| Change | Status |
|---|---|
| Wave 2 CSRD employee threshold raised from 250 to 1,000+ FTE and €450M turnover | Enacted |
| ~80% of companies previously in CSRD scope excluded from mandatory reporting | Enacted |
| Wave 3 (listed SMEs) removed entirely from mandatory CSRD scope | Enacted |
| ESRS mandatory data points reduced by approximately 70% for in-scope companies | Enacted |
| SME VSME voluntary standard retained as optional | Enacted |
In practice: companies that previously expected to file their first CSRD reports for FY 2025 or FY 2026 under Wave 2 — those with 250–999 employees — are no longer legally required to file mandatory CSRD reports under the current legislation.
What the Omnibus does not change
Wave 1 is fully enacted and already in motion. Companies with more than 500 employees were required to file their first CSRD reports covering FY 2024. Approximately 11,700 EU companies across all sectors are now submitting reports that require Scope 3 supply chain disclosures.
The key distinction: Supply chain pull-through demand is not driven by whether the subcontractor must file its own CSRD report. It is driven by whether their customer — the large Wave 1 contractor — must disclose Scope 3 Category 1 emissions in their own report. That requirement exists today, unchanged by the Omnibus.
When BAM Infra, Skanska, or Vinci discloses its Scope 3 Category 1 emissions in their CSRD report, they require verified carbon data from their subcontractor supply chains. This data request flows downstream regardless of the subcontractor's own regulatory status.
Construction subcontractors with 50–249 employees — the segment most affected by the Omnibus threshold change — are not receiving Scope 3 data requests because they themselves need to file. They receive these requests because their customers do.
Three additional demand channels unaffected by the Omnibus
1. EU Taxonomy financing requirements
EU Taxonomy Article 8 disclosure applies to financial market participants — banks, asset managers, pension funds, insurers. These institutions must report on sustainable activities, which requires them to collect verified embodied carbon and ESG data from the construction projects they finance.
Real estate developers, infrastructure funds, and construction project financiers are actively requesting verified ESG data from their construction contractors. Green bond financing, BREEAM certification, and EU-funded public procurement contracts all require verified Scope 3 data. This channel is structurally independent of CSRD scope.
2. Public procurement sustainability requirements
EU public procurement — estimated at 14% of EU GDP — is increasingly embedding ESG criteria and carbon data requirements in tender conditions. The Netherlands StiBAT programme, Germany's Vergaberecht, and Belgium's updated public procurement rules already include sustainability requirements for construction contracts above certain thresholds. These requirements exist at the procurement level, not the corporate reporting level.
3. SaaS economics improve as CSRD simplifies
Traditional ESG consultants built their pricing around complexity — typically €15,000–€40,000 per engagement for a process that maps hundreds of data points to ESRS reporting requirements. If the number of mandatory data points falls by 70%, the consultant's justification for that price weakens. But the SaaS cost structure doesn't change proportionally.
As CSRD reporting becomes simpler, the argument for affordable SaaS tools over expensive consultants strengthens. The Omnibus may reduce regulatory pressure, but it increases the economic case for digital compliance tools.
Market size: what the Omnibus actually changes
The Omnibus changes which companies are legally required to file CSRD reports — not which companies face commercial pressure to provide ESG data to their customers and financiers.
For Tremon's target market of 50–249 employee construction subcontractors in the Netherlands and Germany — approximately 18,000 companies — the commercial demand for verified ESG data is driven by supply chain requests from Wave 1 contractors, not by the subcontractors' own regulatory obligations.
This segment was never the "Wave 2 CSRD compliance" segment. It is the supply chain segment of the Wave 1 compliance market — a distinction that the Omnibus does not affect.
What to do now
If you are a construction company in the Netherlands or Germany and you are currently receiving — or anticipate receiving — Scope 3 data requests from large contractor customers, the appropriate response is the same before and after the Omnibus:
- Understand what Scope 1, 2, and 3 data your customers are asking for and why
- Assess whether your current data collection processes can meet the request
- Evaluate whether automated calculation tools or expert-validated reports are appropriate for your situation
- Consider the cost differential between consulting-led CSRD compliance and platform-based solutions
Tremon's platform is built specifically for this use case: construction subcontractors responding to supply chain ESG data requests, without the overhead of a full-scale consulting engagement.
Explore the Tremon platform → or contact us to discuss your situation