The EU Omnibus I Directive is a simplification of corporate sustainability reporting (CSRD and CSDDD) that entered into force on March 18, 2026. It does not affect Digital Product Passport obligations under the ESPR (Regulation (EU) 2024/1781). DPP timelines, data requirements, and product-level compliance remain entirely unchanged. If you sell physical products into the EU, the headlines about "simplified sustainability rules" apply to corporate reporting — your product-level obligations are on a different track entirely.
What Did the EU Omnibus Actually Change?
On February 26, 2026, the EU published the Omnibus I Directive in the Official Journal, entering into force on March 18, 2026. It amends two pieces of corporate sustainability legislation:
Corporate Sustainability Reporting Directive (CSRD): The reporting threshold was raised to companies with more than 1,000 employees and €450 million in turnover. The European Sustainability Reporting Standards (ESRS) were streamlined significantly — data points cut from 1,073 to approximately 320, a reduction of around 70%. Many previously mandatory disclosures became voluntary. The net effect: far fewer companies need to publish detailed sustainability reports.
Corporate Sustainability Due Diligence Directive (CSDDD): The scope was narrowed to companies with more than 5,000 employees and €1.5 billion in net annual turnover — up from the original thresholds of 1,000 employees and €450 million. The base act remains Directive (EU) 2024/1760, with the transposition deadline extended to July 26, 2028 and compliance required from July 26, 2029.
The ESRS simplification cut mandatory data points from 1,073 to approximately 320. This is the most significant reduction in EU sustainability reporting requirements since the original CSRD was adopted. For companies still in scope, reporting just became substantially easier. But this change is about corporate disclosure — not about the products you sell.
Who Does This Actually Affect?
Here is what matters for small brands: most of you were never in CSRD scope to begin with. The original CSRD applied to companies with 250+ employees and €50 million turnover. The Omnibus raised that to 1,000+ employees and €450 million. If your brand has fewer than 250 employees, the Omnibus changed nothing for you — because the original CSRD already did not apply to you.
The simplification primarily benefits large European enterprises and their compliance teams. For the small brands that PassportCraft serves — brands selling products into the EU market — the relevant regulation has always been the ESPR, not the CSRD. And the ESPR was not touched by the Omnibus.
What Changed vs What Didn't?
This is the critical distinction. Two separate regulatory tracks are moving in parallel, and the Omnibus only affected one of them:
| What Omnibus Simplified (Corporate Reporting) | What Stays the Same (Product Compliance / DPP) |
|---|---|
| CSRD reporting scope narrowed to 1,000+ employees | ESPR scope unchanged — applies to products, not company size |
| ESRS data points cut by ~70% | DPP data requirements unchanged |
| CSDDD due diligence scope reduced to 5,000+ employees | Battery Passport mandate on track for February 2027 |
| Fewer companies need to publish sustainability reports | Every product in scope still needs a Digital Product Passport |
| Company-level disclosure to investors and stakeholders | Product-level data per SKU for consumers, recyclers, and market surveillance |
| Governed by CSRD (Directive) and CSDDD (Directive) | Governed by ESPR (Regulation (EU) 2024/1781) — separate legal instrument |
Why Are DPP and CSRD on Different Tracks?
The distinction comes down to what each regulation targets. CSRD and CSDDD are about corporate disclosure — how a company reports its environmental and social impact to investors, stakeholders, and the public. They are directives, meaning each EU member state must transpose them into national law.
The ESPR is about product compliance — what data must accompany each individual product placed on the EU market. It is a regulation, meaning it applies directly across all member states without transposition. The Digital Product Passport requirement under Article 8(2) of the ESPR attaches to each SKU, not to the company producing it. A brand with five employees selling textiles into the EU faces the same DPP requirements as a brand with 50,000 employees.
There is one area of practical overlap: supply chain data. Companies that already collect environmental and sourcing data for CSRD reporting may find some of that data useful for DPP compliance. But the requirements are distinct, the legal bases are separate, and the timelines are independent.
Unlike CSRD (which has size thresholds), the ESPR contains no general SME exemptions for Digital Product Passport requirements. When a product category's delegated act takes effect, every company selling that product into the EU must comply — regardless of size. The only SME carve-out in the entire ESPR framework is the destruction ban exemption for small and micro enterprises. DPP requirements have no such exemption.
Your DPP Timeline Is Unchanged
None of these deadlines moved. All remain exactly where they were before the Omnibus:
| Deadline | Date | Status |
|---|---|---|
| Destruction ban (large enterprises — clothing, accessories, footwear) | July 19, 2026 | CONFIRMED |
| EU Central DPP Registry operational | July 19, 2026 | EXPECTED |
| Battery Passport mandatory (EV + industrial batteries >2 kWh) | February 18, 2027 | CONFIRMED |
| Textile/apparel delegated act adopted (proposal expected late 2026) | Q1–Q2 2027 | EXPECTED |
| Textile DPP compliance deadline | ~Late 2028/2029 | EXPECTED |
For the full timeline across all product categories, see our complete DPP timeline from 2026 to 2030.
On the digital side, the EU is moving in the opposite direction. A separate legislative package — informally called "Omnibus IV" or the "Digital Omnibus" — is moving through the legislative process with provisions that actually strengthen the Digital Product Passport as a compliance mechanism. The Digital Omnibus aims to make DPP the default vehicle for product safety and market surveillance documentation across the EU. While the EU is simplifying corporate reporting, it is simultaneously investing in product-level digital compliance infrastructure.
What Should You Do Now?
The Omnibus simplification is good news for the European regulatory landscape — but it should not create false comfort about product-level obligations. Here is what we recommend:
-
Don't confuse the two tracks. Corporate sustainability reporting (CSRD/CSDDD) and product compliance (ESPR/DPP) operate under different laws, different timelines, and different scopes. Changes to one do not affect the other.
-
Review your product categories against the ESPR working plan. Textiles, batteries, electronics, furniture, and construction products all have delegated acts in progress. Know which deadlines apply to you.
-
Audit your product data readiness. DPP requirements will demand detailed product-level data — materials, sourcing, care instructions, recyclability. Start collecting this data now, regardless of the exact compliance date. Our DPP preparation checklist can help you identify gaps.
-
Use this window wisely. If the Omnibus reduced your corporate reporting burden, channel that freed-up bandwidth into DPP preparation. The 18+ months needed for implementation means brands should be starting now.
Frequently Asked Questions
Does the EU Omnibus affect Digital Product Passport requirements?
No. The Omnibus I Directive (in force March 18, 2026) simplified corporate sustainability reporting under the CSRD and corporate due diligence under the CSDDD. Digital Product Passport requirements fall under the ESPR (Regulation (EU) 2024/1781) — a completely separate legal instrument. No ESPR provisions were modified, delayed, or simplified by the Omnibus.
Do small businesses get an exemption from DPP requirements?
No. The ESPR contains no general SME exemption for Digital Product Passport requirements. When a delegated act takes effect for a product category, every company placing that product on the EU market must comply, regardless of company size. The only size-based carve-out in the entire ESPR is the destruction ban exemption for small and micro enterprises — and that exemption does not extend to DPP.
When do textile DPP requirements start?
The textile/apparel delegated act is expected to be adopted in Q1–Q2 2027, with a compliance deadline approximately 18 months later (late 2028 or 2029). The European Commission published the preparatory study in December 2025, and a formal proposal is expected in late 2026. These timelines were not affected by the Omnibus.
What is Omnibus IV and does it affect DPP?
Omnibus IV — informally called the "Digital Omnibus" — is a separate legislative proposal that addresses digital compliance across EU product regulations. Unlike Omnibus I (which simplified reporting), Omnibus IV actually strengthens the Digital Product Passport by positioning it as the default "digital by default" mechanism for product safety documentation and market surveillance. It reinforces, rather than relaxes, the EU's commitment to product-level digital compliance.
