CSRD, CSDDD, Omnibus: 3 things that changed and why biodiversity monitoring matters more than ever

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The Omnibus I Directive (EU) 2026/470 entered into force on 18 March 2026. It amends the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). The stated aim is to reduce the regulatory burden on businesses and improve EU competitiveness.

1. The scope shrank dramatically, but the ambition did not

Under the new CSRD thresholds, only companies with more than 1,000 employees and over 450 million euros in annual turnover are required to report. That is up from the previous threshold of 250 employees and 50 million euros. Roughly 80% fewer companies are now in mandatory scope. For the CSDDD, the bar is higher still: 5,000 employees and 1.5 billion euros in turnover, with application pushed to July 2029.

What this does not mean is that nature risk has shrunk. The companies now in mandatory scope are those with the largest supply chains, the biggest land footprints, and the most significant impacts on ecosystems. The regulatory obligation has narrowed to the actors where the stakes are highest.

But these companies will need to (i) map their activities across the value chain and their interactions with nature, (ii) assess the impacts and dependencies of their direct activities and those of their suppliers, (iii) evaluate risks and opportunities, and (iv) develop a mitigation plan. However, for many companies subject to reporting requirements, the impact occurs within the value chain at the production level, since biodiversity is local. These reporting requirements therefore risk trickling down the entire value chain all the way to the producer. This therefore becomes a potential point of differentiation for these companies’ suppliers as their nature strategy will indirectly benefit to their clients.

2. Biodiversity reporting became conditional, which makes the data question more urgent, not less

Under the amended ESRS E4, biodiversity transition plan disclosure is now required only where a plan already exists and has been made public. Policies and targets need only be disclosed if they already exist and relate to identified material impacts.

This sounds like relief. In practice it creates a new challenge. Companies still need a rigorous double materiality assessment to determine whether biodiversity is material at all. That assessment requires actual data on impacts and dependencies at site level.

The amended ESRS E4 is more targeted, not less demanding on evidence. It explicitly requires location-based disclosure. Companies must identify which sites are in or near biodiversity-sensitive areas, with quantitative, traceable metrics and an audit trail that assurance providers can verify.

The phase-in relief that allowed even the largest Wave 1 reporters to omit biodiversity disclosures is closing. From FY2027, in-scope companies where biodiversity is material must disclose against the full E4 framework.

3. The CSDDD now focuses on the most likely risks, and nature is squarely in scope

The simplified CSDDD allows companies to focus due diligence on the areas of their value chain where adverse environmental impacts are most likely. Climate transition plan obligations have been removed. Application starts July 2029.

The core requirement has not changed. In-scope companies must identify, assess, and address actual and potential environmental harms across their operations and supply chains. For agrifood, water, extraction and infrastructure, biodiversity impacts are among the most material risks in scope.

The shift to a risk-based approach rewards companies that already understand where nature-related risks are concentrated. Companies without that evidence will struggle to credibly justify their prioritisation decisions.

What this means if you are not directly in scope

Regulatory scope is one thing. Business reality is another. The 42,000 companies descoped from mandatory CSRD do not operate in isolation. If your client, your investor, or the company buying your products is in scope, they will ask you for nature-related information to fill their own reporting. The trickle-down effect is real and already happening.

The timeline may feel less urgent, but the underlying question is the same: what is actually happening on and around your sites, and can you demonstrate it?

How BeeOdiversity can help

Whether you are preparing an ESRS E4 materiality assessment, mapping risks for CSDDD, or responding to requests from clients and investors in your value chain, the starting point is the same: site-level evidence.

BeeOdiversity combines strategic support and monitoring solutions (remote sensing & ground-level monitoring) to build robust biodiversity baselines that are quantitative, location-based, and traceable over time. We operate worldwide in all sectors.

Get in touch to find out how we can support your reporting, your risk assessment, or your first biodiversity baseline.

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