ESRS E1: climate disclosures, Scope 3 and carbon credits after the Omnibus

Directive (EU) 2026/470, part of the Omnibus I simplification package, entered into force on 18 March 2026. It limits mandatory CSRD reporting to undertakings and groups with more than 1,000 employees on average and net turnover above €450 million. Companies below either threshold fall outside the mandatory scope.

Companies that are not in scope are often still asked for emissions data by customers that are. For those requests, the Omnibus introduces a value-chain cap. A reporting company may not require more than the Commission’s voluntary reporting standard from value-chain companies with up to 1,000 employees, and those companies may decline anything beyond it.

• A transition plan for climate change mitigation, where the company has one, and GHG emissions reduction targets.
• Gross Scope 1, Scope 2 and Scope 3 emissions in tonnes of CO₂e, with Scope 3 reported by significant category.
• Energy consumption and mix.
• GHG removals and GHG mitigation projects financed through carbon credits (disclosure requirement E1-9), reported separately from gross emissions.
• Climate-related physical and transition risks and their anticipated financial effects.

The simplified ESRS keep Scope 3 in E1, reported by significant category. The Omnibus confirms that value-chain information can come directly from suppliers or from estimates, as appropriate, within the value-chain cap. Scope 3 is calculated in line with the GHG Protocol, so changes to the GHG Protocol’s standards over 2027 and 2028 will matter for E1 reporting.