New CSRD rules: more breathing room for strategic impact

What will change?

The decision is an important milestone that not only sets criteria, but also offers new opportunities for companies to strategically embrace ESG.

• Wave 2 (large companies): new criteria:

  • ≥ 1,000 employees and €450 million turnover

  • reporting obligation shifts to 2028 (financial year 2027)

• Wave 1 (listed companies, banks and insurance companies)

  • same thresholds as wave 2

• Wave 3 (listed SMEs)

  • fully exempt

• Wave 4 (non-EU companies)

  • stricter conditions, turnover threshold increased to €450 million EU turnover

No less than 90% of companies fall outside the CSRD reporting obligation, especially organisations from Wave 2. For those companies that do remain within the scope, there is a postponement, but also a clear message. Don't view ESG as a mandatory requirement, but as a strategic lever for growth, trust and market position.

Why does this matter?

The Omnibus amendment significantly reduces the administrative burden for thousands of companies. It gives them time to invest strategically in ESG, rather than merely complying with regulatory requirements. The focus shifts from 'compliance' to value creation. ESG becomes a strategic tool for monitoring, transparency and trust among stakeholders.

What does this mean for your organisation?

For most Flemish SMEs and family-owned businesses, there is no longer a legal reporting obligation. Nevertheless, strategic ESG remains highly relevant.

• ESG is not just about reporting, but about value creation: it strengthens strategy, optimises impact and opens up new business opportunities.

• ESG data plays a key role in investment decisions, partnerships, financing and even winning tenders.

• Companies that use ESG wisely may benefit from improved financing conditions and a stronger brand position.

• Steps already taken, such as the double materiality assessment, remain valuable tools for setting clear priorities.

What’s next for companies still in scope (Wave 2)?

The formal European directive is expected in 2026, after which Belgium will transpose the rules into national legislation by 2027 at the latest. Simplified reporting rules will apply from financial year 2027, with mandatory reporting starting in 2028. Voluntary reporting as from financial year 2026 is the ideal way to gain a competitive head start.

Not sure whether your company is still in scope or how ESG can be used as a lever for value creation? Feel free to contact us for a non-binding analysis.

Summary

These changes are part of the Omnibus Simplification Package introduced on 25 February 2025, aimed at simplifying existing sustainability reporting frameworks (CSRD, CSDDD and the EU Taxonomy).