Omnibus December 2025: what changes
for SME subcontractors.

What the Omnibus changed (and what it didn’t change)

Before the Omnibus, the CSRD was set to gradually extend to all companies with more than 250 employees by 2027. The Omnibus, adopted on December 16, 2025 and published in the EU Official Journal on February 26, 2026, radically changed that trajectory.

What changed: the application thresholds are raised to 1,000 employees and €450 million in revenue. Listed SMEs are excluded. The “Stop the Clock” mechanism (voted in April 2025) delayed the obligations for waves 2 and 3 by two years. Result: about 80% of the companies initially targeted by the CSRD are now exempt.

What didn’t change: companies with more than 1,000 employees remain subject to the CSRD and must report their Scope 3 emissions, meaning the emissions of their entire value chain. And that value chain is their suppliers. You.

Why supplier SMEs are still under pressure

The Omnibus exempts SMEs from the reporting obligation. But it doesn’t eliminate commercial demand. If your client (Stellantis, Renault, Danone, Airbus, Valeo, or any group with more than 1,000 employees) has to report its Scope 3, it needs your data to do so.

In practice, this means you’ll keep receiving carbon questionnaires from your clients. The only post-Omnibus difference is that these questionnaires are now capped by the VSME standard (the “value chain cap”). Your client can no longer demand data from you beyond what the VSME provides for, a simplified framework proportionate to an SME’s resources.

This is real protection, but it doesn’t change the fundamental fact: failing to respond to your client’s carbon request means risking being dropped in favor of a competitor who did respond.

The paradox: less obligation, more pressure

With the Omnibus, SMEs regain control over their climate agenda. There’s no more looming regulatory deadline. No more administrative penalty. This freedom is a relief for many executives.

But it also creates a paradox. Large groups, for their part, remain subject to the CSRD. And without data from their suppliers, they can’t produce their own Scope 3 reporting. The pressure no longer comes from the regulator, it comes from the market.

Tenders increasingly include carbon criteria. Platforms like CDP and EcoVadis have become a required step for certain markets. Banks factor ESG criteria into their risk assessments. The voluntary carbon footprint is becoming a competitive advantage, not a regulatory constraint.

What you need to do, concretely

If you’ve already received a carbon request from your client: respond to it. Use the VSME framework as your reference. The data you need is in your accounting records — Oakbon automatically extracts it from your FEC or your Pennylane or Sage export and produces a report aligned with the GHG Protocol and the ESRS E1 requirements in under two hours.

If you haven’t received a request yet: get ready. Gather your accounting export for fiscal year 2025. Identify which of your clients are subject to the CSRD (more than 1,000 employees). The request will come, and having a carbon footprint ready before it arrives will position you as a trusted supplier.

Either way: don’t confuse “not mandatory” with “not necessary.” The Omnibus frees you from the regulatory obligation, but it doesn’t free you from commercial reality. SMEs that adapt now secure their business relationships. Those that wait are taking a risk.

Key takeaway: The Omnibus is good news for SMEs — it simplifies the framework and caps requirements via the VSME. But the commercial pressure from CSRD-bound clients remains intact. It’s better to prepare for it now, voluntarily, than to be forced into it in a rush by a client.

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