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The Omnibus I Directive took most companies out of the CSRD and limited what large EU customers can demand from smaller suppliers. From financial year 2027, a supplier with 1,000 employees or fewer can be required to provide only the short list of datapoints in the EU voluntary standard for its customer's CSRD report. Requests made under other laws, and data the supplier chooses to share, are a separate matter.
What Omnibus I changed in the CSRD
Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026 and entered into force in March 2026. Member States must transpose its CSRD provisions by 19 March 2027. It followed the Stop-the-clock Directive (EU) 2025/794 of April 2025, which had already postponed the second and third waves by two years.
The headline changes are these.
- Mandatory reporting only for EU companies and groups with more than 1,000 employees and more than EUR 450 million net turnover, with both tests met.
- Listed SMEs removed from mandatory scope.
- Non-EU groups in scope only with more than EUR 450 million EU net turnover in each of the last two years and an EU subsidiary or branch above EUR 200 million, reporting from financial year 2028.
- A value chain cap protecting companies with 1,000 employees or fewer from data requests beyond the voluntary standard.
- Limited assurance kept, reasonable assurance dropped, and binding sector standards replaced by non-binding guidance.
The ESRS were rewritten in parallel. The revised set, Delegated Regulation (EU) 2026/1563, applies from financial year 2027 and removes around 61% of mandatory datapoints.
Is your company in CSRD scope
For a typical Turkish exporter the answer is no. The table summarises the position as of October 2026.
| Your situation | Direct CSRD obligation | What you will be asked for |
|---|---|---|
| Turkish company selling to EU customers, no EU entity | None | Value chain data from customers, capped from FY2027 if you have 1,000 employees or fewer |
| Turkish company with an EU sales subsidiary below the thresholds | None for the subsidiary | Same as above |
| Turkish group with more than EUR 450 million EU turnover and an EU subsidiary or branch above EUR 200 million | Group report from FY2028, published in 2029 | Full group data under the standards for non-EU groups, still being drafted |
| Turkish subsidiary of an in-scope EU group | None directly | Data for the parent's consolidated statement, not covered by the cap |
The last row is often misunderstood. A subsidiary inside the consolidation is part of the reporting group, not an external value chain partner, so the parent can and will ask for the full data set its ESRS statement needs.
The value chain cap explained
The cap rests on a new voluntary sustainability reporting standard, adopted as Delegated Regulation (EU) 2026/1560 and in force since 24 September 2026. It is based on the VSME, which the Commission published as Recommendation (EU) 2025/1710 in July 2025, with only limited changes to fit the revised ESRS.
From financial years beginning on or after 1 January 2027, a CSRD reporter cannot require a value chain company with an average of 1,000 employees or fewer to provide information beyond the datapoints in Annex II of that standard. The protected company may refuse anything more, and contract clauses that require more are ineffective. Customers may still ask, and suppliers may still choose to answer.
The cap only applies to information gathered for the customer's own CSRD sustainability statement. Where data is missing, the revised ESRS let the customer use estimates and sector averages, and report metrics for only part of its value chain.
What the VSME datapoints look like
The exact cap list is in Annex II of Delegated Regulation (EU) 2026/1560, so check the final text before you build a response. In practice it follows the core disclosures of the VSME Basic Module, which a small manufacturer can usually complete within a few weeks.
| Area | Typical datapoints |
|---|---|
| Basis of preparation | Legal form, sites, sector codes, turnover, headcount, certifications |
| Practices and policies | Whether policies exist on climate, pollution, water, resources, workforce and business conduct |
| Energy and greenhouse gas | Energy use in MWh by renewable and non-renewable source, Scope 1 and location-based Scope 2 emissions, GHG intensity |
| Pollution | Emissions to air, water and soil where already reported under permits |
| Biodiversity | Sites in or near sensitive areas, land use |
| Water | Water withdrawal, and consumption for water-intensive processes |
| Resource use and waste | Total waste, hazardous waste, share recycled |
| Workforce | Employees by contract type and gender, turnover rate, accidents, fatalities, training hours, collective bargaining coverage, pay |
| Business conduct | Convictions and fines for corruption and bribery |
Scope 1 and Scope 2 emissions are the item suppliers most often lack. A short corporate inventory under ISO 14064-1, described on our corporate carbon footprint page, solves this once and is reused every year.
What EU customers can still ask for outside the cap
The cap is narrower than many suppliers hope. It does not restrict information needed to comply with other EU or national law. Examples relevant to Turkish exporters include the following.
- CBAM. EU importers of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity need installation-level embedded emissions data from the producer. See our CBAM consulting service.
- EU Deforestation Regulation. Operators need geolocation and due diligence data for covered commodities such as wood, rubber, cattle, cocoa, coffee, palm oil and soy.
- Batteries Regulation. Carbon footprint and due diligence data for batteries and battery materials.
- CSDDD. The amended Corporate Sustainability Due Diligence Directive applies from 26 July 2029 to EU companies with more than 5,000 employees and EUR 1.5 billion turnover. Business partners may be asked for information, with extra safeguards for those below 5,000 employees.
Commercial requests also continue. A customer may prefer suppliers with a CDP score, an EcoVadis medal or a product carbon footprint, and that is a purchasing decision rather than a legal demand. The cap tells you what you can be forced to give for CSRD purposes. It does not tell you what will win the contract.
Key dates for suppliers
| Date | What happens |
|---|---|
| 16 April 2025 | Stop-the-clock Directive (EU) 2025/794 published, delaying the second and third CSRD waves by two years |
| 30 July 2025 | VSME published as Commission Recommendation (EU) 2025/1710 |
| 26 February 2026 | Omnibus I Directive (EU) 2026/470 published in the Official Journal |
| 21 September 2026 | Revised ESRS and the voluntary standard published in the Official Journal |
| 24 September 2026 | Voluntary standard, Delegated Regulation (EU) 2026/1560, in force |
| 1 January 2027 | Financial years from this date fall under the new thresholds, the revised ESRS and the value chain cap |
| 19 March 2027 | Deadline for Member States to transpose the CSRD changes |
| 1 January 2028 | First financial year for non-EU groups that meet the EU turnover test |
| 26 July 2029 | Amended CSDDD starts to apply to the largest companies |
The practical consequence is that customer requests in 2027 will mostly concern 2026 data, before the cap applies. Expect the cap to shape questionnaires sent from 2028 onwards, covering financial year 2027. Customers that rebuild their supplier surveys around the VSME now will avoid disputes with suppliers later.
How a Turkish supplier should prepare
- List every sustainability request received in the last two years and sort them by legal basis (CSRD, CBAM, other law or commercial).
- Check your average headcount. At 1,000 employees or fewer you are protected by the cap for CSRD-driven requests from financial year 2027.
- Prepare the VSME Basic Module data for the last full year, with the source evidence behind each figure.
- Calculate Scope 1 and 2 emissions under ISO 14064-1 or the GHG Protocol, and keep the emission factors consistent across all responses.
- Write short policies where they are missing, but only where you can show they are applied.
- Publish or share a standard VSME-based report and point customers to it, rather than filling in each template from zero.
Most of this can be done in four to eight weeks for a single-site company. Groups with several plants, or with CBAM-covered products, need longer because installation-level data has to be built at the same time.
Where suppliers still face full ESRS requests
Two groups will see little relief. Turkish subsidiaries of in-scope EU groups must deliver whatever the parent's ESRS statement needs. Turkish groups that meet the non-EU test must prepare for a full group report on financial year 2028, and the two-year turnover look-back means 2026 and 2027 already count.
For both, our CSRD and ESRS reporting service covers subsidiary data packs and group readiness. Companies comparing their options across GRI, TSRS, CDP and VSME can start with our ESG reporting frameworks comparison.
Ekol Çevre engineering team
Environmental engineers and consultants based in İzmir, Ankara and Kocaeli.