Navigating new legislation is rarely straightforward, even when its intentions are clear. The Corporate Sustainability Reporting Directive (CSRD) is the European Union's most significant step yet towards improving corporate transparency and accountability on sustainability. It mandates companies to disclose detailed information about their environmental, social, and governance (ESG) performance, a crucial development for industries like food and consumer goods, where supply chain complexity makes compliance particularly challenging.

However, the CSRD has undergone substantial changes in 2025 and 2026 as part of the EU's Omnibus I simplification package, which was formally signed into law in February 2026. If you were tracking the original scope and timelines, much of what you knew has changed. Here is an up-to-date overview of what the CSRD requires, who it now applies to, and how companies in the food industry should be thinking about it.

What is the CSRD?

The CSRD builds on the foundation of the Non-Financial Reporting Directive (NFRD), taking a more comprehensive approach to ESG reporting. Its core aim is to establish a unified reporting framework that allows stakeholders to compare ESG performance across companies operating within the EU.

Following the Omnibus I reforms, the scope has been significantly narrowed. The directive now applies to EU companies that meet both of the following thresholds:

• More than 1,000 employees

• More than €450 million in net annual turnover

This is a major shift from the original criteria. Listed SMEs and financial holding companies are no longer automatically in scope, and smaller companies in the supply chain now have greater protections against being asked to report by larger in-scope companies (more on this below).

Companies that fall outside these thresholds may still choose to report voluntarily. The EU has developed a voluntary standard for SMEs (VSME) to support this, and proactive reporting can still be a meaningful signal to customers and partners.

What does this mean for food companies?

For food companies that meet the revised thresholds, the CSRD introduces real reporting obligations, and real challenges. Supply chains in this sector are inherently complex, often spanning multiple countries and involving many smaller suppliers, which makes ESG data collection particularly demanding.

That said, the Omnibus reforms have introduced one important relief for the industry: the value chain cap. Smaller suppliers, those with fewer than 1,000 employees now have the legal right to decline requests for sustainability information that goes beyond what is covered by voluntary reporting standards. This limits the trickle-down burden that large companies can place on their supply base.

For companies that are in scope, however, the expectations remain significant. And even for those that are not currently in scope, the direction of travel is clear. Customers, investors, and retail partners increasingly expect visibility into sustainability performance regardless of regulatory obligations.

Key Timeline Updates

The reporting schedule has also shifted considerably:

• Wave 1 companies (large listed companies and public interest entities already covered by the NFRD) are reporting now, covering financial year 2024.

• Wave 2 companies (those meeting the revised thresholds of 1,000+ employees and €450m+ turnover) now have their first report due in 2028, covering financial year 2027 — a two-year delay from the original schedule.

• Wave 3 (listed SMEs) effectively no longer exists under the revised scope, as these companies no longer meet the new thresholds.

The reporting standards themselves have also been simplified. The revised European Sustainability Reporting Standards (ESRS) reduce the number of mandatory disclosure datapoints by around 61%, making the reporting framework more focused and manageable for those that do need to comply.

How Simvia can help

A practical way to address these requirements is through smarter supply chain compliance management. This means tools that enable genuine collaboration with suppliers while reducing the administrative burden on them.

Simvia offers exactly that.

Sustainability Risk Assessment Simvia's risk assessment tools allow you to evaluate social and environmental risk across your supply chain using 21 leading databases, from the World Bank to the WWF Water Risk Filter. The assessment includes specific risk scores for food products based on their potential environmental impact, and is used by leading organisations including the Sustainability Initiative Fruit and Vegetables, Greenyard, and the Colruyt Group.

Live Compliance Monitoring Mitigating risk requires visibility. Simvia provides a live overview of valid and invalid certifications, questionnaires, and declarations across your supplier network. It also automates the collection of supplier questionnaires and certificates, significantly reducing manual follow-up and keeping your compliance picture up to date.

How to Prepare

Even with the delays and scope reductions, there are strong reasons to start preparing now. Companies that build their sustainability data capabilities early will face far less disruption when reporting obligations do apply — and will be better positioned to respond to customer and partner expectations in the meantime.

Most preparation comes down to three key areas:

1. Risk Assessment Understanding where ESG risks exist across your supply chain is the foundation of CSRD compliance. This means assessing environmental, social, and governance risks at both a company and supplier level — and being able to demonstrate that assessment to auditors and stakeholders.

2. Integrated Reporting The CSRD requires sustainability data to be reported alongside financial data. Building internal processes that connect these two streams early will save significant effort down the line.

3. Double Materiality Assessment One of the CSRD's most distinctive requirements is the double materiality assessment. Companies must evaluate both how sustainability issues affect their business, and how their business affects people and the environment. This takes time to do properly, so starting early, even ahead of a formal obligation is worthwhile.

How Simvia Can Help

A practical way to address these requirements — particularly within fresh produce — is through smarter supply chain compliance management. This means tools that enable genuine collaboration with suppliers while reducing the administrative burden on them.

Simvia offers exactly that.

Sustainability Risk Assessment Simvia's risk assessment tools allow you to evaluate social and environmental risk across your supply chain using 18 leading databases, from the World Bank to the WWF Water Risk Filter. The assessment includes specific risk scores tailored to fresh produce products based on their potential environmental impact, and is used by leading organisations including the Sustainability Initiative Fruit and Vegetables, Greenyard, and the Colruyt Group.

Live Compliance Monitoring Mitigating risk requires visibility. Simvia provides a live overview of valid and invalid certifications, questionnaires, and declarations across your supplier network. It also automates the collection of supplier questionnaires and certificates, significantly reducing manual follow-up and keeping your compliance picture current.

A Chance to Lead

The CSRD even in its revised, simplified form is more than a regulatory obligation. For companies willing to engage with it seriously, it is an opportunity to demonstrate leadership on sustainability and build a more resilient, transparent supply chain for the long term.

The regulatory landscape will continue to evolve, and the companies investing in their sustainability infrastructure now will be better prepared and better positioned than those that wait.

To find out how Simvia's solutions can support your CSRD compliance journey, visit our products page.