Sustainability in the EU: Important News from the European legislation
What Really Changes for SMEs
In recent years, European sustainability legislation has shifted from a transparency-focused approach to a more structured system of obligations and standards. With the Omnibus I Directive1 the European Union is now aiming to reduce complexity and limit administrative burdens, especially for smaller businesses.
A key milestone was reached on February 24, 2026, when the European Council formally adopted the reform updating sustainability reporting and due diligence requirements. In terms of the institutional calendar, the update will enter into force on the twentieth day following its publication in the Official Journal of the EU.
So, Who will be Required to Comply with the CSRD (Corporate Sustainability Reporting Directive)2?
The scope is significantly narrowed. Sustainability reporting will only become mandatory for EU companies with an average of more than 1,000 employees and annual net sales exceeding EUR 450 million.
The threshold also applies to certain non-EU entities: in fact, the rules will also include companies from non-EU countries with a net turnover of more than EUR 450 million in the EU, as well as their branches and subsidiaries with a turnover of more than EUR 200 million in the Union.
At the same time, the “ancillary” rules are also changing: reporting requirements will be reduced and sectoral reporting will become voluntary.
SMEs are Exempt from Reporting Requirements
For many SMEs, the most important news is related to the “cascade” effect along the supply chain. No transfer of reporting responsibility to companies with fewer than 1,000 employees.
In fact, companies with fewer than 1,000 employees will no longer be required to provide larger companies with which they collaborate with additional information beyond that required by voluntary reporting standards.
This is where the European voluntary VSME standard3 designed for SMEs comes into play.
The VSME was submitted by EFRAG4 as technical advice to the European Commission on December 17, 2024, and adopted by the European Commission through Recommendation (EU) 2025/1710 of July 30, 2025.
CS3D5 Duty of Care: Deferred and Limited Obligations
The directive is also clear on the duty of care: it only applies to very large companies and with a more relaxed timeline. Only large companies with more than 5,000 employees and an annual net turnover of more than EUR 1.5 billion will be required to exercise due diligence.
As for “when,” the date is explicit: the due diligence directive will come into force on July 26, 2029, for all companies concerned.
Less Bureaucracy, More Simplicity
Simplification is not just a matter of thresholds. Omnibus I was created with the stated aim of reducing complexity, particularly for SMEs and small mid-caps.
Among the operational measures, there is one that is very concrete for those who need to navigate rules and documentation: to facilitate compliance with the new rules, EFRAG has set up a digital platform, the EFRAG knowledge hub, which provides access to guidance on national and EU reporting requirements, including templates for documents to be submitted.
And on the subject of standards (ESRS6) another piece of the puzzle is falling into place: in 2025, the European Commission tasked EFRAG with providing technical advice on how to simplify the delegated act relating to ESRS by November 2025.
EFRAG published the draft of the amended ESRS on December 3, 2025, following extensive public consultation.
Concluding Remarks
For most SMEs, the message is twofold: on the one hand, there does not appear to be any immediate new obligation to report in a “CSRD-style”; on the other hand, the market (banks, large customers, supply chains) will continue to request ESG information in a more or less structured manner.
In this context, aligning national instruments with European standards can help reduce duplication and inconsistent requests. The Ministry of Economy and Finance has published an update to the Document for Sustainability Dialogue between SMEs and Banks, publishing a table showing the interoperability between this document and the voluntary European VSME standard developed by EFRAG.
When properly implemented, voluntary reporting clarifies priorities, makes objectives measurable, and facilitates dialogue with stakeholders and financial partners. It also makes it easier to identify critical issues in business processes and helps to find solutions.
In a constantly evolving landscape, the point is not to “report,” but to choose how to turn sustainability into a competitive advantage, with an approach proportionate to the size of the company.
Donatella Vitanza e Marianna Fabbri
Glossary:
- The Omnibus Directive (EU) 2025/794 (often referred to as Omnibus I in the context of sustainability) is a European Union directive adopted on April 14, 2025, amending Directives (EU) 2022/2464 (CSRD) and (EU) 2024/1760 (CSDDD) with regard to the dates of application of certain sustainability reporting and due diligence obligations. The text is published in the Official Journal of the European Union L 2025/794 of April 16, 2025.
- The Corporate Sustainability Reporting Directive (CSRD) is an EU regulation (Directive 2022/2464) in force since 2023 that requires companies to publish detailed and standardized reports on their environmental, social, and governance (ESG) impacts.
- The Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME) is a voluntary framework developed for sustainability (ESG) reporting tailored to SMEs not subject to CSRD requirements.
- The European Financial Reporting Advisory Group (EFRAG) is a private organization, established in 2001 and supported by the EU, which provides technical advice to the European Commission. Its main role is to define accounting standards (IFRS) and, crucially, the European Sustainability Reporting Standards (ESRS) for sustainability reporting (ESG) required by the CSRD directive.
- The CS3D (Corporate Sustainability Due Diligence Directive), also known as CSDDD or Directive (EU) 2024/1760, is a European regulation that came into force in July 2024, requiring large companies to monitor and mitigate negative impacts on human rights and the environment throughout their value chain (including suppliers).
- The European Sustainability Reporting Standards (ESRS) are mandatory ESG reporting standards defined by EFRAG for the CSRD directive, which came into force in the EU at the beginning of 2024 for large companies. They require the disclosure of transparent information on environmental (E), social (S), and governance (G) impacts, including two cross-cutting standards and ten thematic standards (e.g., climate, pollution, biodiversity).


