The rules for sustainability reporting in Europe have undergone significant changes with the adoption of the "Sustainability Omnibus". This exercise amended the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D). The goal was to make reporting obligations simpler and exempt more businesses, while preserving the overarching goals of the European Green Deal. The Sustainability Omnibus was finalized in December 2025, and published in the EU's Official Journal in February 2026.

What changed for CSRD and CS3D?

The Sustainability Omnibus narrows the scope of companies required to comply with the CSRD and CS3D and simplifies reporting obligations aiming to reduce costs and administrative burdens, particularly for smaller businesses. This legislative revision aligns with the European Commission's broader agenda to make the EU more competitive and business-oriented.

The objective is to target the companies that are considered the most consequential in terms of ESG impacts, and that are seen as capable of absorbing the costs of reporting.

Here are the main changes to each one of the texts:

Corporate Sustainability Reporting Directive (CSRD):

• Reduction of scope: Companies must now meet higher thresholds to fall under the CSRD requirements, having at least 1,000 employees and a net turnover above €450 million. The same turnover threshold applies to non-EU companies. The businesses below these thresholds can conduct voluntary sustainability reporting. A review clause in the text also allows the Commission to evaluate future expansions of the scope.
• Simplified reporting standards: Reporting standards will become more focused on quantitative information, and transition plans will be simplified. EFRAG (European Financial Reporting Advisory Group) already delivered the draft simplified standards as technical advice to the European Commission. The Commission is expected to adopt them no later than six months after the entry into force of the Omnibus legislative provisions.
• No sector-specific reporting: Sector-specific reporting requirements have been removed. That means that there will be no media-specific reporting obligations. Instead, the European Commission will provide optional sector-specific guidance for companies applying ESRS (European Sustainability Reporting Standards), including support for the Double Materiality Assessment exercise.
• Exclusions from reporting: In addition to information that could seriously harm their commercial position, companies may also omit sensitive information, such as trade secrets, intellectual property, sensitive innovation-related information, classified information, and data that could threaten security or privacy.
• Exemptions for small and medium-sized companies: Large companies interacting with small and medium-sized companies in their supply chain face new limits on data demands. This “value-chain cap” prevents disproportionate requests for information from companies with fewer than 1,000 employees.
• Limited assurance of sustainability reporting: The requirement for reasonable assurance standards has been removed in order to lower compliance costs and administrative burdens. Furthermore, the adoption of limited assurance standards has been postponed to 1 July 2027.

Corporate Sustainability Due Diligence Directive (CS3D):

• Reduction of the scope: The due diligence obligation now applies only to companies with more than 5,000 employees and a global net turnover exceeding €1.5 billion, including non-EU corporations with corresponding turnover generated in the EU.
• A new scoping exercise: Companies must now conduct a scoping exercise based solely on reasonably available information to identify areas where adverse impact is most likely to occur. Based on the results of that exercise, companies will be required to conduct an in-depth assessment to understand the nature, extent, causes, severity and likelihood of the adverse impacts.
• Repeal of Climate Transition Plans: The provisions requiring the adoption and implementation of transition plans for climate change mitigation under the CS3D have been repealed, as they were considered disproportionate and a source of legal uncertainty.
• Limiting accountability: The liability regime has been simplified, and the maximum limit for financial penalties has been set at 3% of global net turnover. The European Commission is also expected to provide guidelines to assist supervisory authorities in determining the levels of penalties. The uniform EU-wide liability regime has been removed, leaving liability to existing national laws.
• Entry into force postponed: The European Commission will adopt general due diligence guidelines by 26 July 2027, and in parallel, the deadline of application of the CS3D for all companies will be postponed to 26 July 2029.

What does this mean for public service media organisations?

While these changes have reduced the number of public service media (PSM) companies obliged to report and audit their value chains, some others will remain under the scope of mandatory reporting.

Many public broadcasters have already undertaken valuable work in assessing their sustainability impact. For PSM who fall outside the revised scope, this existing groundwork can still form the basis for voluntary reporting and can be important in case they are involved in supply chains of other reporting companies, contributing to the broader ecosystem of organisations that comply with EU standards.

Voluntary sustainability practices offer a chance to enhance their reputation and demonstrate a commitment to ethical, social, and environmental values. Beyond compliance, sustainability reporting promotes transparency, builds public trust and is an opportunity to showcase the role PSM plays in promoting social impact, ethical practices, and environmental responsibility.