2025 was a year of uncertainty. In 2026, the path forward is clearer. 

This is our updated guide to Sustainability Reporting post-Omnibus, built on real experience from supporting customers across multiple industries. It includes a practical roadmap to help your organization move forward, whether you’re working with CSRD, voluntary ESRS or VSME, or strengthening your internal sustainability work. We have helped many teams navigate this shift already, and we are ready to help you do the same.

CSRD post-Omnibus: what has changed?

On 16 December 2025, the European Parliament formally endorsed key elements of the European Commission’s Omnibus simplification package, originally released in February 2025. CSRD obligations, including application of the European Sustainability Reporting Standards (ESRS), now applies only to EU companies and groups that meet both of the following criteria:

• more than 1,000 employees, and

• net turnover above EUR 450 million.

  
  

Companies falling outside the CSRD scope are expected to adopt a voluntary sustainability reporting standard, such as Voluntary ESRS or VSME, depending on size.

Now what?

For many mid-sized organisations, the Omnibus decision means less immediate legal pressure under CSRD, but continued expectations on sustainability transparency from customers, banks, investors, and partners. This leaves organizations outside the CSRD scope with several options: to stay within the CSRD lane, to adopt voluntary reporting (e.g., via VSME or selected ESRS elements), or to personalize reporting even further. The sky is the limit. 

To help you navigate this changing landscape, we have compiled a roadmap explaining different alternatives and what they could mean for your organization. Depending on where you are today, your ambition and your risk tolerance, we are happy to guide you to the right path. 

Sustainability reporting options post-Omnibus

Broadly, companies now fall into one of three approaches: starting with climate fundamentals, staying aligned with full ESRS, or adopting lighter voluntary standards such as VSME.

Climate Reporting using the GHG protocol

Establishing a solid process and clear structure for your climate reporting is an excellent first step. This fundamental data, including your GHG calculations, is a common requirement and asset for most reporting frameworks. You can build a strong foundation by starting with your Scope 1 and 2 emissions, then progressively incorporating relevant categories from Scope 3. To learn more about the GHG protocol, click here.

SustainLab’s support: Our climate module supports the calculation of emissions (Scope 1, 2, and Scope 3) using recognized standards (GHG protocol or ISO). We can support you with setting organisational and operational boundaries, getting a data strategy going, or defining what scope 3 categories you need. If you also need help with SBTi, transition plans, or other climate-related support, we are here as well!

Once climate data is in place, the next step is deciding how closely you want to align with European sustainability standards.

Stay in the CSRD lane – go full speed ahead with 2023 or 2026 ESRS 

Staying in the CSRD lane means continuing with your original plan and implementing the full CSRD and ESRS standards as intended. You're choosing to utilise your already made investments, despite changes in the regulatory timeline. This approach is ideal for companies that are still in scope but with a new timeline, or those that want to show leadership and future-proof their reporting. 

SustainLab’s support: Our CSRD module helps you collect data and report in line with all relevant ESRS standards – accurately, on time, and with high quality.

Voluntary ESRS 

If your company is no longer in scope for CSRD reporting but is above 250 employees, we recommend reporting voluntarily against the ESRS standards, ensuring you are following a recognised framework, whilst maintaining a focus on value-adding metrics and disclosures. Start where you are and disclose the data that you can access, and align with the parts that matter most. This helps you gain value quickly and get a clear roadmap forward for your unique reporting strategy. A good place to start is the Double Materiality Analysis (DMA), but it can also be about finding the alignment with areas that matter most to your business model.

SustainLab’s support: Our platform is built for flexibility. You can start with specific ESRS datapoints – like climate or workforce – and expand your reporting step by step as needed. We can support with advice on where to start, what to defer, and how to set up a process that you can build on!

VSME – the standard for small and medium enterprises 

VSME is recommended for organisations with up to 250 employees, and this path is suitable for companies that want to report in a structured framework adapted to their reality. Using the VSME framework is an excellent starting point for companies that are new to collecting and reporting sustainability data, and want to ensure they have a good basis to also report data in their value chain, to their stakeholders and have an internal understanding.

SustainLab’s support: Our platform supports you with both the Data Collection for VSME and reporting against templates. We also add support and consultancy if needed, and can give you guidance or tailored services, for example, our “Sustainability Controller as a Service”, to support smaller teams with data quality. 

VSME + 

The VSME standard is a good option to ensure you have a solid sustainability reporting process if you are within the recommended size. But, regardless of that, you may want to add disclosures or data points to the foundation to make sure you have the set-up that adds the most value. Perhaps industry or company specific metrics? We can support you with that as well!

SustainLab’s support: Our platform lets you add your own KPIs and tailored fields to the VSME report. You get the best of both worlds – the structure of VSME plus the specifics that matter to your business. Our customer Blentagruppen is a powerful example of how flexibility can align with a complex value chain and a large need for independence.

VSME with or without Scope 3?

When reporting on climate, you might face the decision of whether to include Scope 3 emissions (indirect value chain emissions) or just stick to Scope 1 and 2. VSME allows flexibility here. Holding off on Scope 3 might make sense if data is hard to access or your supply chain is complex. On the other hand, measuring some Scope 3 categories now strengthens your climate strategy and can meet demands from customers already fully reporting.

SustainLab’s support: Our modular GHG solution allows you to start with Scope 1 and 2 and add Scope 3 later as your data and needs evolve. All calculations follow the GHG Protocol and are visualized for internal tracking and external reporting.

Do your needs expand the common frameworks? 

The options we have listed above are common standards, but we know that many organisations also have other reporting frameworks, target verifications, benchmarks or internal needs. We can always support you in reporting parallel to or only in the platform with solutions such as SBTi, CDP, GRESB, etc.

SustainLabs support: The power of our platform lies in its flexibility, allowing us to support you in establishing more efficient reporting flows for streamlined data collection for more than one need. Our customer success team is ready to guide you on the optimal approach: collecting data once and leveraging it for all your subsequent requirements. Contact us or book a demo today to discover more.

Choosing your lane doesn’t have to be overwhelming. 

It’s about picking the option that best fits your current situation and ambition. Whether you move forward with full CSRD or take an alternative route, you’re still heading in the direction of greater transparency and sustainability. 

SustainLab is here to support you on that journey - whichever lane you choose - so you can keep driving sustainability efforts with clarity and confidence. 

Ready to map your route? → Book a meeting