The CSRD wave has changed shape: automating ESG reporting without losing your soul (or your compliance)

In short.
The Omnibus package has cut the mandatory scope of the CSRD by almost 90%. Demand for non-financial data, however, has not gone away: it has shifted from the regulator to the companies placing orders. Falling outside the legal scope therefore does not exempt you from knowing how to answer.

The mandatory scope has shrunk by almost 90%. But demand for ESG data has not gone away: it has moved. Here is what really changed in 2026, and how to prepare for it intelligently.

For two years, a tidal wave was forecast: the CSRD, the European directive on sustainability reporting, was to require around 50,000 companies to publish detailed non-financial information. Many organisations launched heavy projects to get ready.

Then the landscape turned around. The simplification package known as “Omnibus I”, adopted at the end of 2025, published in the Official Journal of the EU in February 2026 and in force since March 2026, profoundly reshaped the framework. The mandatory scope was reduced by around 90%. Thresholds went up. Deadlines slipped. For many mid-sized companies that thought they were affected, the question became: “are we still in scope?”

The answer deserves nuance and, above all, it hides a trap that this article sets out to shed light on.

What the Omnibus actually changed

Three major shifts, without going into the technical detail.

The scope has narrowed to large companies. Mandatory reporting now mainly targets EU companies that exceed both 1,000 employees and €450 million in net turnover. Listed SMEs, originally in scope, have left the mandatory scope. The result: from around 50,000 companies affected down to a few thousand.

The timetable has been pushed back. A so-called “stop-the-clock” measure postponed by two years the entry of “wave 2” companies, whose first reports now cover the 2027 financial year and will be published in 2028. The new thresholds apply to financial years starting on or after 1 January 2027.

The standards themselves have been lightened. The ESRS (the framework setting out what must be published) are being simplified, with an expected reduction of around 70% in the number of data points to report. The simplified version is expected during 2026, to apply from the 2027 financial year.

At first sight, it is a relief. Many companies tell themselves “phew, this is no longer for us”. That is exactly where the trap closes.

The trap: leaving the mandatory scope does not make the demand disappear

Here is what a quick reading misses. The CSRD does not create the demand for ESG data: it formalises it for the largest companies. But those large groups, which remain in scope, must report on their value chain. And to do so, they turn to their suppliers, subcontractors and partners: in other words, to a multitude of smaller companies that have left the mandatory scope.

Add to this the banks (which require ESG data for their own obligations and their lending decisions), investors, key-account customers and public buyers, who increasingly build sustainability criteria into their tenders.

A counter-intuitive conclusion: even if your company is no longer required to publish a CSRD report, it will receive ESG questionnaires from its customers, its banks and its value chain. The directive does provide safeguards (companies with fewer than 1,000 employees can limit what they are asked for to a lighter voluntary standard, the VSME), but the pressure to provide comparable non-financial data is very real and here to stay.

The mandatory wave has receded. The wave of demand, driven by the value chain, keeps rising.

So the real issue: answering ESG questionnaires quickly and accurately

Whether you are within the mandatory scope (and must produce a defensible report) or outside it (but approached by your customers and banks), the operational need converges: gathering scattered ESG data, answering rigorously, and being able to prove it.

And it is painful work, for familiar reasons. The information is scattered: HR, purchasing, energy, finance, quality. Questionnaires repeat from one customer to the next, without ever being quite identical. And the reliability stakes are serious: an environmental figure that is wrong or unsourced may tomorrow count as “greenwashing” and expose the company.

Automation therefore makes complete sense, on one essential condition: not losing your soul. In other words, not sacrificing accuracy and traceability on the altar of speed.

Automating “without losing your soul”: what it means

In the ESG field, a bad automation tool is more dangerous than useful. If it generates plausible but invented answers, it mass-produces greenwashing. Three principles separate the useful tool from the risky one.

Sourcing. Every published data point must be tied to its evidence: the original document, the page, the date. In sustainability matters, an unsourced claim is not merely weak: it is legally exposed.

Abstention. When a data point does not exist or is not reliable, the tool must flag it, not fabricate it. “Data not available” is an honest answer; an invented figure is a fault.

Capitalisation. Approved answers must feed a reusable base, so that the next ESG questionnaire (there will be others) starts with a head start rather than from scratch.

What a specialised platform adds

This is exactly what a platform such as Optivalue.ai offers, and it is what makes it relevant in this new context. Rather than generating answers “by guesswork”, it draws on your internal documents, sources each answer with its precise reference, abstains when no reliable data exists, and capitalises approved answers in a reusable base. Whether you are preparing a report within the mandatory framework or answering the questionnaires of your major customers and your banks, you save the time spent on collection while keeping answers defensible. Automation in the service of rigour, not in its place, which is exactly what a field demands where a careless claim can backfire on you.

Key takeaways

The Omnibus has not killed the CSRD: it has refocused it on the largest companies, lightened it and spread it over time. But it would be naive to conclude that ESG is fading as a subject. Demand for non-financial data does not depend on the law alone: it is now woven into commercial relationships, financing and tenders.

The real question in 2026 is therefore no longer “am I obliged to report?” but “am I able to answer, quickly and defensibly, the ESG questionnaires that will keep pouring in?”. Companies that organise themselves now (by structuring their data and equipping themselves with tools that source and capitalise) will turn a constraint into an advantage. The others will find themselves, with every customer request, improvising answers they cannot prove.

FAQ: CSRD, Omnibus and ESG reporting in 2026

Is my company still covered by the CSRD after the Omnibus?Mandatory reporting now mainly targets EU companies that exceed both 1,000 employees and €450 million in net turnover. Many mid-sized companies and listed SMEs have left the mandatory scope. It remains essential to check your precise situation, as transitional rules and options left to Member States apply.

If I am no longer in the mandatory scope, can I stop dealing with ESG?No. Even outside the mandatory scope, you will probably be approached by your major customers, your banks and your value chain, who need comparable sustainability data for their own obligations. The demand is moving from the law to commercial relationships.

What is the VSME?It is a voluntary, lighter sustainability reporting standard for SMEs, adopted at European level to offer a simple framework to those outside the mandatory scope that must nonetheless answer requests for information. Companies with fewer than 1,000 employees can rely on it to limit what they can be asked for.

When do the new rules apply?The new scope thresholds apply to financial years starting on or after 1 January 2027. The simplified version of the ESRS is expected during 2026, to apply from the 2027 financial year, with the option of early adoption.

Can you trust an AI to produce ESG data?Provided it sources every answer (document, page, date) and abstains rather than invents when no reliable data exists. A general-purpose AI that “fills in the gaps” is a greenwashing risk; an AI designed for traceability is, on the contrary, a compliance asset.

How can you avoid unintentional greenwashing with automation?By allowing no unsourced claim, by having answers approved by the people responsible, and by keeping the evidence for every published data point. Automation should speed up collection, never replace human verification.

This article is provided for information purposes and does not constitute legal or regulatory advice. The CSRD framework is evolving; to determine your exact obligations, refer to the official EU texts, their national transposition, and a qualified professional.

Answer ESG questionnaires without improvising

Optivalue.ai gathers your scattered sustainability data, sources each answer with its reference, abstains when no reliable data exists, and capitalises your approved answers. Whether you are within the mandatory scope or approached by your customers and banks, you answer quickly, and you can prove it.

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