Sustainability reporting in 2026 after the EU Omnibus

We clarify the obligations and the different sustainability reporting options from 2026 onwards

Sustainability reports have entered a new phase. Following the recent regulatory adjustments to the CSRD Directive at European level, the scope of companies required to report has been narrowed down to large corporations. However, this regulatory simplification does not reduce the strategic relevance of these reports or their impact on business management.

Large companies: sustainability reporting under the CSRD

Following the recent approval of the Omnibus package, organisations in the European Union that, for two consecutive years, have more than 1,000 employees and a net turnover exceeding €450 million must prepare a sustainability report in accordance with the requirements of the CSRD (Corporate Sustainability Reporting Directive). It also applies to non-EU companies that, at group or individual level, have generated a net turnover of more than €450 million in the EU, as well as to European subsidiaries with a net turnover exceeding €200 million. The first CSRD report must be published in 2028, covering the 2027 financial year.

The content of the report will be set out in the ESRS (European Sustainability Reporting Standards), which are due to be approved in the coming months. What is clear is that disclosure requirements will be drastically reduced compared with the CSRD’s original approach. In any case, all companies within this group should start preparing now to comply with the CSRD.

Finally, it should be noted that the CSRD must be transposed into Spanish law within 12 months of the Omnibus package being published in the Official Journal of the EU, so it will be important to keep an eye on any nuances introduced by the Spanish legislator.

VSME: a practical benchmark for companies not subject to mandatory reporting

In the current regulatory environment, the VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs), developed by the European technical body EFRAG, is particularly relevant.

This voluntary standard is aimed at non-listed micro, small and medium-sized enterprises that fall outside the mandatory scope of the CSRD. Its purpose is to provide a structured and proportionate framework for responding to requests for ESG information from customers, banks or investors, without taking on the technical complexity of the ESRS. We believe this is the model with the greatest future potential in the European Union for all organisations not covered by the CSRD.

What about companies already preparing an EINF?

The Non-Financial Information Statement (EINF, by its Spanish acronym) is the mandatory report that certain companies in Spain must submit under Law 11/2018. It applies to companies with more than 250 employees that are either public-interest entities or exceed certain financial thresholds (net turnover above €40 million or total assets above €20 million).

Pending Spain’s position on the transposition of the CSRD, companies within this group must continue to prepare their Non-Financial Information Statement (EINF). Accordingly, in 2026 they must prepare and verify their 2025 EINF, following the same process as in previous years.

And what about organisations already reporting under GRI?

GRI (Global Reporting Initiative) is a voluntary international standard that provides a clearly structured framework for preparing sustainability reports. It is the most widely used model worldwide and allows performance to be compared across organisations. It can be used by any organisation that wishes to report its sustainability information, regardless of its size or sector.

Since companies subject to the CSRD will have to comply with the Directive, we expect GRI to remain the benchmark model outside the European Union and for organisations operating in global markets.

Beyond compliance: reporting as a management tool

Ultimately, the new European landscape redefines the scope of the obligation, but it does not diminish the strategic importance of ESG reporting. Reporting reaches its full potential when it stops being a standalone document and becomes a reflection of business strategy. This means linking reported information to specific, measurable objectives, monitoring indicators, action plans and clearly defined governance.

Sustainability information is not just a matter of regulatory compliance. It is a management tool that improves decision-making, strengthens resilience and consolidates competitive positioning in an increasingly demanding business environment.