The EU Omnibus package is now law. After months of negotiation, the European Parliament approved the agreement in December 2025, the Council gave final sign-off on February 24, 2026, and the directive entered into force on March 18, 2026.
For food businesses that have been tracking CSRD compliance timelines, the Omnibus changes are significant—and the picture is more nuanced than most headlines suggest. Fewer companies will be in mandatory scope. But the reporting obligations for those that remain are unchanged in substance, and the supply chain dynamics that were already pushing food businesses toward Scope 3 reporting haven't gone away.
This post covers what the Omnibus changed, who is now in scope, and what it actually means for food businesses still navigating their reporting obligations.
The EU Omnibus I is a package of amendments to EU sustainability legislation introduced by the European Commission in February 2025. It proceeded in two stages. The first was the Stop-the-Clock Directive, adopted in April 2025, which postponed by two years the CSRD reporting requirements for Wave 2 and 3 companies. The second was the substantive amending directive—revising scope thresholds, reporting obligations, and value chain provisions—which was adopted on 24 February 2026 and entered into force on 18 March 2026.
For companies focused on sustainability reporting, the most important changes are to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). Both have been significantly scaled back in scope.
UK food businesses with SECR obligations will find the two frameworks draw on the same underlying data—for a full guide to SECR requirements, see SECR Reporting for Food Businesses.
The most consequential change for most companies: CSRD now applies only to companies with more than 1,000 employees and more than €450 million in net annual turnover.
The previous scope would have extended to companies with 250+ employees and €40 million turnover, meaning tens of thousands of mid-sized European businesses were on track to become subject to mandatory CSRD reporting. The Omnibus removes most of them from the obligation entirely.
For reference, the original CSRD rollout was structured in waves:
• Wave 1 (large listed companies, >500 employees): reporting from FY2024
• Wave 2 (large non-listed companies, >250 employees, >€40M turnover): reporting from FY2025
• Wave 3 (listed SMEs): reporting from FY2026
Under the Omnibus, Wave 2 and Wave 3 reporting has been deferred by two years, and many Wave 2 companies will no longer qualify under the new thresholds at all.
Wave 1 companies—those that had to start reporting from the financial year 2024—that now fall below the new thresholds have been granted a transition exemption for 2025 and 2026.
One of the most practically significant changes is the introduction of a value chain cap. Under the revised rules, companies within the reporting scope can only request limited sustainability information from suppliers and value chain partners that fall below 1,000 employees. Those smaller businesses have the legal right to refuse information requests beyond a voluntary simplified reporting standard. The forthcoming voluntary standard will be based on the existing VSME (Voluntary SME Reporting Standard). For food businesses not in scope, but where providing sustainability to their suppliers provide competitive advantage, VSME provides a practical, proportionate framework.
This matters for food businesses in scope: it limits how much data you can formally demand from your ingredient suppliers, particularly smaller producers and farms. In practice, the shift places more emphasis on using third-party emissions databases and modeled emission factors—rather than supplier-reported data—to calculate Scope 3 Category 1.
For companies still in mandatory scope, the core reporting requirements remain. Scope 1, 2, and 3 disclosure is still required under ESRS E1. Double materiality assessment is still required. The methodology must still be auditable and aligned with recognized standards, like the GHG Protocol. For food businesses above the new thresholds, the Omnibus changes the question of who reports, not how.
The value chain cap protects smaller suppliers from mandatory reporting demands. But it doesn't change the commercial reality that large food companies with their own CSRD obligations still need Scope 3 Category 1 data—they'll just need to obtain it through other means (databases, estimates, or voluntary supplier partnerships) rather than formal requests.
For food businesses supplying large corporate clients, the buyer-driven push for emissions data is likely to continue regardless of regulatory status. Corporate clients with SBTi commitments need to account for their own Scope 3 Category 1, which means your emissions as a supplier are part of someone else's mandatory report.
Science-Based Targets are a voluntary commitment made directly to SBTi. The Omnibus has no effect on companies' SBTi obligations. Food businesses that have committed to science-based targets—including FLAG targets for agricultural and land-use emissions—are still bound by those commitments regardless of whether CSRD applies to them.
For businesses that choose to continue reporting voluntarily, the VSME standard provides a proportionate framework—lightweight enough to be practical for smaller operators, and structured enough to satisfy the data requests of larger clients still in mandatory CSRD scope.
If you were in Wave 1 (>500 employees, reporting from FY2024) and remain above the new thresholds: Your reporting obligations are unchanged. The Omnibus tightened the value chain data you can formally demand from suppliers, but your own reporting requirements are the same in substance.
If you were in Wave 2 and are now below the 1,000-employee / €450M turnover threshold: You are no longer in mandatory CSRD scope under the revised rules. The two-year deferral also applies if you fall in a grey zone. That said, if you have SBTi commitments or corporate clients requiring Scope 3 data, the practical need to measure and report your food emissions is likely unchanged.
If you were preparing voluntarily (not yet in mandatory scope): The Omnibus reduces the near-term regulatory pressure, but not the competitive and commercial reasons to track food emissions. Sustainability credentials increasingly affect procurement outcomes, partner relationships, and access to investment—particularly in the enterprise food and catering sector.
For food businesses that remain in mandatory CSRD scope, the core challenge is unchanged: Scope 3 Category 1—the carbon embedded in purchased ingredients—is almost always material under double materiality assessment, and it is the most data-intensive category to calculate credibly.
Spend-based estimates alone are unlikely to meet the audit scrutiny CSRD requires for Scope 3 Category 1 in food businesses. The directive requires a documented, auditable methodology applied consistently across reporting periods. For food operators, where Category 1 is almost always material, spend-based proxies cannot distinguish between ingredients with very different emission profiles—making them inadequate for the level of precision CSRD verification demands, even if not explicitly prohibited.
The value chain cap introduced by the Omnibus actually increases the importance of having a robust internal data foundation—one that doesn't depend on suppliers voluntarily providing figures that many are now legally entitled to withhold.
For a full breakdown of how CSRD Scope 3 reporting works for food businesses, see CSRD for the Food Industry. For guidance on building the underlying data foundation, see Sustainability Reporting for Food Businesses.
Q: Does the EU Omnibus mean CSRD no longer applies to food businesses?
A: Not for large food companies. The Omnibus raised the mandatory reporting threshold to companies with more than 1,000 employees and more than €450 million in net annual turnover, which removes many mid-sized businesses from scope. Large food businesses above those thresholds are still required to report under CSRD, including full Scope 1, 2, and 3 disclosure under ESRS E1. For businesses that have fallen out of mandatory scope, supply chain and client-driven pressures mean many will continue reporting voluntarily. See CSRD for the Food Industry for a full breakdown of what the directive requires.
Q: What is the EU Omnibus and when did it come into force?
A: The EU Omnibus (Omnibus I) is a package of amendments to EU sustainability legislation, primarily targeting the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). The European Parliament approved the final agreement on December 16, 2025, and the Council of the EU gave formal sign-off on February 24, 2026. The directive was published in the Official Journal on February 26, 2026 and entered into force on March 18, 2026. Member states have 12 months to transpose its provisions into national legislation.
Q: Does the Omnibus change Scope 3 reporting requirements for food businesses in scope?
A: No. For companies still within mandatory CSRD scope, Scope 3 reporting requirements under ESRS E1 are unchanged. Material Scope 3 categories—which for food businesses almost always include Category 1 purchased goods—must still be disclosed with auditable, methodology-backed data. What changed is who is in scope, not what in-scope companies are required to report.
Q: What is the value chain cap introduced by the Omnibus?
A: The value chain cap limits what companies in mandatory CSRD scope can formally request from suppliers and value chain partners with fewer than 1,000 employees. Those smaller businesses now have a legal right to refuse information requests beyond a forthcoming voluntary simplified reporting standard. For food businesses, this means more reliance on third-party emissions databases and LCA-derived emission factors for Scope 3 Category 1 calculation, rather than direct supplier-reported data.
Q: If we fall below the new CSRD thresholds, do we still need to measure our Scope 3 emissions?
A: Not under CSRD—but the commercial, client-driven, and SBTi-related reasons to do so may remain. Large corporate clients with their own mandatory CSRD reporting need Scope 3 Category 1 data from their suppliers. If you supply companies in mandatory scope, your emissions appear in their reports whether you report them yourself or not. Science-Based Target commitments are also independent of CSRD and unaffected by the Omnibus.
Q: What should food businesses do now in response to the Omnibus?
A: First, confirm whether you remain in mandatory CSRD scope under the new thresholds (>1,000 employees and >€450M turnover). If yes, your reporting obligations are unchanged—focus on building an activity-based Scope 3 data foundation aligned with ESRS E1. If you've fallen out of mandatory scope, assess your voluntary reporting position against client expectations, SBTi commitments, and procurement requirements. For practical next steps, download the Carbon Readiness Blueprint or see how Klimato's Scope 3 reporting tools support food businesses at both ends of the compliance spectrum.
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Klimato Food Emissions calculates ingredient-level FLAG emissions—the land-use and agriculture impact embedded in your food procurement—alongside full Scope 3 Category 1 reporting, aligned with CSRD and SBTi.