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Omnibus: if you have fewer than 1,000 employees, this is what you will still be asked for

23 September 2026Voombu8 min read

Outside CSRD does not mean outside ESG data

After Omnibus, a company below 1,000 employees may fall outside direct CSRD obligations. Its in-scope customers, banks and funds still need information for their own risk management and reporting.

VSME and the data cap

VSME provides a proportionate response language. Regulation limits what may be requested from companies below 1,000 employees so the value chain does not pass the full ESRS burden downstream.

What will still arrive

Footprint and reduction plans for financing, social and governance data for supplier approval, climate risks, and DNSH evidence for European funding. The answer should be created once and reused.

An illustrative unlisted company with 400 employees and €60M revenue has no direct CSRD obligation after Omnibus, but retains EINF while applicable and receives VSME, banking and DNSH pressure. Voombu activates Core and DNSH per action; extended frameworks only when requested.

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