The Omnibus I Directive entered into force on 18 March 2026. Here is what actually changed — and why the data collection imperative for maritime companies has not disappeared.
The Corporate Sustainability Reporting Directive (CSRD) was adopted in 2022 to require large European companies to disclose detailed sustainability information — including Scope 1, 2, and 3 greenhouse gas emissions — using a standardised set of reporting standards known as the European Sustainability Reporting Standards (ESRS).
In February 2026, the European Commission published the Omnibus I Directive: a significant revision package designed to reduce the administrative burden of CSRD and the related Corporate Sustainability Due Diligence Directive (CSDDD). After passing through the European Parliament and Council, the Omnibus I Directive entered into force on 18 March 2026.
For maritime companies — shipowners, operators, OEMs, and suppliers — the changes are material. This post explains what actually changed and what it means in practice.
Under the original CSRD, the directive applied to all large EU companies meeting two of three criteria: more than 250 employees, more than €40 million in turnover, or more than €20 million on the balance sheet. Listed SMEs were also due to be phased in.
The Omnibus raises the threshold substantially. CSRD now applies to EU companies with more than 1,000 employees and a net turnover exceeding €450 million. Listed SMEs are removed from scope entirely.
The result: approximately 80% of the companies originally in scope are no longer required to report under CSRD.
Companies that were part of Wave 2 — large companies that had not yet started reporting — were due to publish their first CSRD report in 2026 covering financial year 2025. The Omnibus introduces a two-year stop-the-clock measure. These companies now have until 2028 to publish their first report, covering financial year 2027.
The original ESRS framework contained 1,073 individual data points. The simplified ESRS, submitted by EFRAG to the European Commission in late 2025, cuts this to approximately 320. Double materiality — the requirement to assess both how your company impacts the environment and how environmental risks affect your business — remains mandatory. However, the expectation shifts from volume to judgement: fewer data points, clearer reasoning on what is material.
One of the most practically significant changes for maritime supply chains is the introduction of a value-chain cap. CSRD-reporting companies may no longer demand sustainability data from smaller suppliers beyond what is covered by the forthcoming Voluntary SME Standard (VSME). In practice, this means a large shipowner cannot require its equipment suppliers to provide full ESRS-level data if those suppliers have fewer than 1,000 employees.
The Commission will publish the content of the VSME voluntary standards by July 2026.
The original CSRD included plans for sector-specific ESRS standards, including for the maritime and shipping sector. These have been discontinued under the Omnibus simplification. Companies will rely on the general ESRS framework and apply materiality judgement to sector-relevant topics.
If you are a large shipping company — with more than 1,000 employees and more than €450 million in annual turnover — your CSRD obligations remain in force. The Omnibus does not remove your reporting requirement; it simplifies the format and, for Wave 2 companies, delays the first reporting year.
Scope 3 GHG emissions remain mandatory where they are material. For maritime operators, Scope 3 emissions — covering vessel construction, spare parts procurement, fuel supply chains, and ship management — typically represent the largest share of total emissions. The obligation to collect and report this data has not gone away.
What has changed is the data quality threshold. The simplified ESRS allows greater use of estimates and proxy data for Scope 3, reducing pressure to achieve full activity-based data across every spend category immediately. However, as CSRD reporting becomes subject to third-party assurance, the expectation will move towards higher-quality, verifiable data over time.
If you are a maritime equipment supplier, component manufacturer, or service provider with fewer than 1,000 employees, the Omnibus is genuinely good news: your customers can no longer require you to provide full ESRS-level sustainability data.
But this does not mean the pressure disappears.
Large shipowners and operators who remain in scope will still need Scope 3 data for their own CSRD reports. They will request data from their suppliers — the difference is that those requests must now stay within the bounds of the VSME voluntary standard. Once the VSME content is published in mid-2026, suppliers will have a clearer picture of exactly what is expected.
More importantly, product-level carbon footprint and lifecycle assessment (LCA) data is increasingly becoming a commercial differentiator in maritime procurement. Customers asking for verified LCA data are not necessarily driven by CSRD alone — they are responding to EU Green Claims regulation, FuelEU Maritime well-to-wake requirements, and their own decarbonisation targets. Suppliers with certified, ISO-compliant product carbon footprint data will have an advantage in tendering processes regardless of the CSRD threshold.
The most important thing to understand about the Omnibus simplification is this: it changed who is required to report, not what good climate data looks like.
Companies that invested in building robust Scope 3 data infrastructure — activity-based emissions tracking, product-level LCA calculations, certified EPDs — are better positioned under the simplified ESRS, not worse. Their data meets a higher evidentiary standard than estimates. It supports green claims under EU regulation. It satisfies customer procurement requirements. And it prepares them for the next phase of regulatory tightening, which will come.
For companies that were previously uncertain whether to invest in emissions data collection, the Omnibus reduces short-term compliance pressure but does not change the underlying direction of travel. The IMO's 2050 net-zero strategy, FuelEU Maritime, and EU ETS for shipping are all moving in the same direction. The infrastructure you build for Scope 3 data today will serve multiple regulatory purposes over the next decade.
No. Scope 3 emissions reporting remains mandatory for companies within CSRD scope where those emissions are material. The Omnibus allows greater use of estimation and proxy data in the short term, but does not eliminate the requirement.
Wave 2 companies now have until 2028 to publish their first CSRD report (covering FY2027). This gives you additional time to build your data infrastructure — but not unlimited time. Starting your LCA and Scope 3 data collection process now will put you in a significantly stronger position than waiting until 2027.
You are no longer required to report under CSRD. However, your large customers who remain in scope will still request sustainability data from you — within the limits of the forthcoming VSME voluntary standard. Having certified product carbon footprint data is also increasingly a commercial requirement in maritime procurement independent of CSRD.
The Voluntary SME Standard (VSME) is a simplified sustainability reporting framework being developed by the European Commission for companies outside CSRD scope. The Commission is required to publish the VSME content by July 2026. It will define the maximum level of sustainability data that CSRD-reporting companies can request from smaller suppliers under the value-chain cap.
ReFlow's platform — ClimateHub and EmissionPassport — generates ISO-compliant product-level LCA and Scope 3 data that meets ESRS E1 quality requirements. For maritime companies, this includes vessel lifecycle assessments, product carbon footprints for components and spare parts, and procurement-integrated Scope 3 tracking through the EmissionPassport integration with ProcureShip.