CSRD, ESRS and the double materiality assessment (after Omnibus I)

What is it?

The Corporate Sustainability Reporting Directive is the EU reporting obligation for sustainability disclosure. After the Omnibus I package of 24 February 2026 it looks considerably different from the version originally adopted. The Omnibus reduced the scope by around 90 per cent: only companies with at least 1,000 employees and more than €450 million in revenue now have to report. That takes most mid-sized manufacturers of construction products out of the direct obligation.

What has not changed methodologically are the European Sustainability Reporting Standards (ESRS), currently 12 standards across the cross-cutting, environmental, social and governance blocks, and the double materiality assessment (DMA). The DMA is the mandatory methodological exercise at the start of every ESRS report. It establishes which topics the company has to report at all, either because the company has significant impacts on people and the environment (impact materiality) or because a topic is financially material for the company (financial materiality). Without a dependable DMA there is no dependable ESRS report.

For the construction products industry the product-related anchors are ESRS E1 (climate change) and ESRS E5 (resources and circular economy). E1 requires Scope 1, 2 and 3 greenhouse gas inventories, and EPDs, LCAs and PCFs supply the data building block for Scope 3.1 (purchased goods) and Scope 3.11 (use phase). E5 requires data on recycled content, material inputs, waste and service life. Modules C and D of the EPDs to EN 15804 provide the end-of-life data basis here.

Who is affected?

Since Omnibus I, only large companies with at least 1,000 employees and more than €450 million in revenue are directly obliged to report. For the large majority of construction product manufacturers, typically mid-sized, the direct reporting obligation therefore falls away. Third-country companies with more than €450 million in EU revenue have to report from financial year 2030.

Indirectly, though, the CSRD stays effective for every manufacturer. Reporting customers, clients, investors and banks continue to ask for Scope 3 data, because their own reporting depends on it. Failing to supply it means dropping out of supplier selection processes and out of ESG-assessed awards. Building owners in sustainability-oriented projects, along with architecture and planning offices working with BNB, QNG or DGNB certification, also require product-specific life cycle and climate data regardless of whether the supplier has its own CSRD obligation.

Which deadline applies?

The important dates after Omnibus I.

• 24 February 2026: the Omnibus I package is finally adopted and the new set of obliged companies is fixed.
• 19 March 2027: deadline for transposing the Omnibus I changes into national law.
• Financial year 2030: the reporting obligation starts for third-country companies with more than €450 million in EU revenue.

In parallel EFRAG is revising ESRS Set 1. Refinements and additions are to be expected over the coming years, but the core methodological requirements (DMA, E1, E5) remain stable. Anyone set up for those data points will get through the EFRAG updates without structural change.

What has to be done?

For manufacturers of construction products two clearly separate routes emerge.

Route A, companies above the Omnibus threshold (1,000+ employees and more than €450 million revenue):

• Set up and document the DMA: stakeholder consultation, materiality matrix and reasoning. An external auditor will only accept a dependable method with data provenance that can be followed.
• Build the ESRS E1 data basis: Scope 1, 2 and 3. Scope 3.1 (purchased goods) and 3.11 (use) take their data basis from product-specific LCAs, EPDs and PCFs.
• The ESRS E5 route: recycled content, material inputs, waste and service life assumptions. This data comes from modules C and D of the EPDs to EN 15804.
• Prepare for limited assurance: external auditors ask for methodological evidence, data provenance and consolidation rules. Limited assurance is the entry-level depth of audit, with reasonable assurance following at a later stage.

Route B, companies below the threshold:

• Supply Scope 3 data to reporting customers even without your own obligation, because customers and clients ask for it. Being unable to answer means dropping off supplier lists.
• Produce product-specific EPDs as a data source you can communicate with, not only as a compliance duty but as a sales and supply chain asset.
• Use the DMA voluntarily as a strategic tool to sort your own climate, social and governance risks methodically. If you later cross the threshold into the obligation, the groundwork is already done.

What happens if you do not?

Companies under a direct obligation face sanctions under the relevant national implementing law. The German draft implementing act provides for fines of up to €10 million or 5 per cent of annual revenue. Often heavier than the fine is the market effect: missing or faulty reports lead to qualifications in the management report, investors and banks actively evaluate the reports, and sustainable finance terms deteriorate.

For manufacturers without an obligation there is no legal risk, but an increasingly hard market risk. Anyone who cannot answer the Scope 3 requests of their reporting customers drops off those customers’ supplier lists, particularly in ESG-driven segments. Banks and insurers increasingly factor sustainability data into the terms of financing and insurance. Without product-specific data you are counted against average values and lose the competitive advantage your own optimisation work paid for.