After the Omnibus: what changes for advisory teams

For two years, sustainability advisory work in Europe had a simple engine: the CSRD was coming, thousands of companies had to be ready, and every one of them needed a double materiality assessment, a gap analysis and a data plan. The Omnibus has changed that engine. Directive (EU) 2026/470 raised the thresholds to more than 1,000 employees and more than €450 million turnover. The revised ESRS, published in September 2026, cut the mandatory datapoints sharply.

It is tempting to read this as the end of the boom. It is better read as a change in where the work sits.

1. The remaining reporters need better reports, not first reports

The companies still in scope are the largest and most scrutinised. Many already reported under Set 1. Their question is no longer "how do we comply?" but "how do we make this report shorter, sharper and assurable?" That is a different engagement. It rewards people who can judge materiality, write clearly and defend a judgement to an auditor, rather than people who can fill a datapoint template.

2. The companies that dropped out still have customers

Most former wave-two companies are now outside the CSRD. But their banks, insurers and large customers still need data. The voluntary standard for smaller companies, published alongside the revised ESRS, gives them a format, and the Omnibus caps what large companies can request from partners with up to 1,000 employees. These companies need help deciding what to report voluntarily and setting up the basic data once, so they can answer many requests. The projects are smaller, but there are many more of them.

3. Regulation did not stop at the CSRD

CBAM payments start for 2026 imports. The EUDR applies to large operators from 30 December 2026. The packaging regulation started applying in August 2026. The UK, Australia and California all have their own reporting timelines. Clients increasingly need someone who can see across these regimes and reuse the same data for several of them.

4. Strategy is back in the room

When reporting dominated the agenda, sustainability strategy often became "what do we need to disclose?" With the pressure reduced, the better clients are asking a different question: "what would we do if nobody was asking?" Transition plans, supplier programmes and product redesign are where real value, and real emissions reductions, sit.

What this means for skills

• Judgement over volume. Explaining why a topic is not material is now as valuable as documenting why one is.
• Multi-regime fluency. One climate dataset, mapped to the ESRS, ISSB-based standards and customer requests.
• Plain writing. Shorter reports put every sentence under more scrutiny.
• Commercial sense. Clients will pay for work that saves them money or wins them customers, not only for compliance.

The Omnibus reduced the paperwork. It did not reduce the problems the paperwork was meant to describe. Advisory teams that move with the work will find plenty of it.

Educational content, not legal advice.