Omnibus I: Future Sustainability Reporting – Impact on Swiss Companies

The following table summarises the main changes:

Category	Existing CSRD Scope	Agreed Changes
EU based companies	EU entities or groups that exceed at least two of the following size criteria: 250 employees €50 million net turnover €25 million total balance sheet	Annual reporting from 2028 for financial year starting 1. January 2027 for all EU entities or groups with: More than 1,000 employees More than €450 million net turnover This includes companies that are not PIEs and companies that did not fall under NFRD reporting requirements but fulfil the above criteria
Non-EU Companies	Non-EU entities are required to report on a global consolidated basis if they have consolidated turnover exceeding €150 million in the EU; and either: a subsidiary in the EU within the CSRD scope or a branch in the EU with turnover exceeding €40 million	Annual reporting from 2029 for financial year starting 1. January 2028for non-EU entities on a global consolidated basis if they have: consolidated turnover exceeding €450 million in the EU for the preceding two financial years; and a subsidiary or a branch in the EU with turnover exceeding €200 million in the preceding financial year
SMEs	Listed SMEs subject to annual CSRD reporting.	Exclusion of listed SMEs from CSRD reporting.
Value Chain	No cap on information requests from smaller companies in the value chain.	Value-Chain-Cap: Companies in the value chain with less than 1000 employees may refuse information requests that exceed the Voluntary Reporting Standard für SME (VSME)
Assurance requirements	Limited assurance in the initial years of reporting, moving to reasonable assurance. EC to adopt assurance standard by 2026.	Limited assurance only Adoption of assurance standards postponed to 1 July 2027.
Sector Specific Standards	Sector specific standards expected to be adopted by 2026 (approximately 40 sector specific standards planned)	Requirement to issue sector-based standards is removed EC may provide sector-specific guidance if there is demand from entities subject to CSRD in a specific sector

 

Additionally, the Omnibus agreement introduces a new exemption for parent companies of groups that are “financial holding companies,” allowing them to choose whether to report consolidated sustainability information or omit it. However, this exemption is strictly limited:

Definition of "Financial Holding Companies"

“Financial holding undertakings” are undertakings “with the sole object to acquire holdings in other undertakings and to manage such holdings and turn them to profit, without involving themselves directly or indirectly in the management of those undertakings, without prejudice to their rights as shareholders”

Note: Additionally, the reporting obligation remains in place for individual companies within the group if they are subject to reporting requirements themselves.

 

Introduction of Simplified ESRS (ESRS Set 2.0)

Submission of the Recommendation

In parallel with the Omnibus process, EFRAG submitted its technical recommendation for simplified ESRS (ESRS Set 2.0) to the EU Commission on December 3, 2025.

Entry into Force and Application

• The EU Commission will adopt a delegated act for the mandatory application of the simplified ESRS starting from the financial year 2027.
• Wave 1 companies that fall under the scope of the CSRD before 2027 can voluntarily apply the simplified ESRS standard as early as the financial year 2026.

 

Voluntary Reporting Standard for SMEs (VSME)

Recommendation of the EU Commission

Additionally, the EU Commission recommends that companies not falling under the scope of the CSRD voluntarily report according to the Voluntary Standard for Micro, Small, and Medium-sized Enterprises (VSME).

The VSME provides SMEs with a simpler, standardized basis for sustainability disclosures – particularly helpful for requests from customers, banks, and supply chain partners. The Commission will formally adopt the VSME standard in 2026 through a delegated act.

 

How can Swiss companies or groups be affected by the CSRD?

Swiss companies or groups can be either directly affected by the CSRD in two ways:

• EU subsidiaries or EU sub-holdings of Swiss companies with more than 1,000 employees consolidated and net turnover of at least €450 million need to publish an ESRS sustainability statement for FY 2027 in 2028.
• Swiss companies that have a consolidated net turnover in the EU greater than €450 million and having an EU Branch or subsidiary that has net turnover of €200 million need to publish a sustainability report covering its global operations for FY 2028 in 2029. This report must be published in accordance with the nESRS Standard (European Sustainability Reporting Standard for non-EU parent companies) which is expected to be published in October 2027 by the EU Commission.

 

Swiss companies that do not meet the above criteria are generally exempt from CSRD reporting. Nevertheless, in practice they will often have to provide data because customers and suppliers in the EU are subject to CSRD requirements and demand information from the value chain.

Those who want to respond to these requests quickly and consistently should consider the VSME standard. It offers SMEs a simple, standardised introduction to sustainability reporting and is recommended by the European Commission as a voluntary solution for companies outside the CSRD.

 

What can be expected next?

The EU aims to publish the changes to the CSRD in the Official Journal of the EU by the middle of 2026. Member states will then have 12 months to transpose them into national law. At the same time, the European Commission is reviewing the EFRAG proposal for a simplified ESRS and is expected to launch a four-week consultation on the delegated act in February. The ‘Omnibus’ agreement requires the European Commission to adopt the delegated act on the simplified ESRS as soon as possible and no later than six months of the entry into force of the ‘Omnibus’ agreement. Hence the delegated act with the simplified ESRS is also expected to be published by the middle of 2026.

 

How BDO Switzerland Helps SMEs in Sustainability Reporting

If you have any questions regarding Swiss sustainability reporting OR 964, implications of the Omnibus I agreement for your company or require clarification regarding the simplified ESRS standard, feel free to contact us at sustainability@bdo.ch