Insights · As of September 2026
Omnibus and NaBeG: who still has to report from 2027?
The reporting obligation under the Corporate Sustainability Reporting Directive (CSRD) has shrunk considerably. Here is who remains in scope, and what stays relevant for everyone else.
What changes under the Omnibus
The Omnibus Directive (EU) 2026/470 of the European Union limits the direct CSRD reporting obligation to large, non-listed companies.
- In scope are companies with more than 1,000 employees.
- In addition, revenue must exceed €450 million.
- Both thresholds must be met together.
The change is expected to apply from financial year 2027.
Austria has already adopted the relief
The Austrian Sustainability Reporting Act (NaBeG, Nachhaltigkeitsberichtsgesetz, Federal Law Gazette I No. 6/2026) transposes the Omnibus Directive into Austrian law. The narrower reporting obligation therefore also applies to companies based in Austria.
A further amendment to the NaBeG is expected in autumn 2026. We will update this article once it is available.
What stays relevant without a reporting obligation
Companies that are no longer directly required to report still receive requests: from banks, from large customers, from partners along the supply chain.
- Section 243ba of the Austrian Commercial Code (UGB, Unternehmensgesetzbuch) limits what companies subject to reporting may demand from their value-chain partners.
- Within these limits, metrics and evidence remain in demand, even without your own CSRD obligation.
What this means for you
- Check whether you exceed or fall below both thresholds.
- Expect requests from business partners, even without your own reporting obligation.
- We support you with a scope check and with preparing the relevant metrics.
As of September 2026; the legal situation may change.