Omnibus: How to take advantage of the two year reporting delay

The European Commission's Omnibus proposal triggered a two-year delay for CSRD reporting for Wave 2 and 3 companies, and a scale-back for Wave 1 companies. If you're in Wave 2 or 3, this gives you more time—but it doesn't mean you should stop. Here's how to use the delay well.

What the delay means in practice

The CSRD was originally set to require Wave 2 companies (large non-listed companies meeting two of: 250+ employees, €50M+ revenue, €25M+ assets) to start reporting on FY2025 data, with Wave 3 (listed SMEs) to follow. The Omnibus proposal pushes these deadlines back by two years and also raises the employee threshold from 250 to 1,000, potentially removing many Wave 2 companies from scope entirely.

For companies still in scope, the delay means more time to build your data infrastructure, refine your double materiality assessment, and develop your reporting processes. For companies potentially leaving scope, it's worth tracking developments closely—the final legislation hasn't been adopted yet.

Don't stop: use the time strategically

The worst thing you can do is pause entirely. Companies that treated CSRD preparation as just a compliance exercise are now at risk of having wasted that work. The better move is to reframe it as building genuine management capability.

The Omnibus proposal has not changed the underlying business case for sustainability management: customers, investors, and banks are still asking for this data. If anything, VSME-level reporting is now more standardized, meaning your supply chain customers will ask for structured data whether or not you're directly regulated.

Five ways to use the delay well

1. Complete your double materiality assessment

This is the foundation of everything. Even if reporting is delayed, your DMA determines what you need to track. Companies that have completed a rigorous DMA are far better positioned when reporting does begin. The EFRAG simplification of ESRS may reduce some data point requirements, but the DMA itself remains central.

2. Build clean data infrastructure

The most common reason companies struggle with CSRD reporting is poor underlying data. Use the delay to connect your carbon accounting, HR, and operational data to a single reporting environment. This is the hardest part and takes the longest—starting now is an advantage.

3. Train your internal teams

CSRD requires collaboration across finance, legal, operations, and sustainability. The delay is an opportunity to build cross-functional understanding before reporting pressure hits. Run internal workshops, assign ownership, and start practicing the disclosure process.

4. Engage your supply chain

Scope 3 data from suppliers is notoriously hard to collect. Use the extra time to build supplier engagement programs, send data requests, and improve the quality of your upstream emissions data. This pays dividends whether you're reporting under CSRD or responding to customer questionnaires.

5. Pilot a dry run

Produce an internal CSRD-aligned report for FY2024 or FY2025, even if you're not required to publish it. This reveals gaps, clarifies ownership, and gives your auditors and assurance providers something concrete to work with ahead of the real deadline.

What Coolset recommends

For Wave 2 and 3 companies, we recommend continuing your CSRD preparation at a measured pace rather than stopping. Focus on the DMA, data infrastructure, and stakeholder engagement. These activities have value regardless of the final regulatory outcome. Get in touch to see how Coolset can support you.