Following the release of the Omnibus package on sustainability legislation, the dominant market reaction was predictable: \u201cSustainability reporting is no longer relevant to us.\u201d For most companies in Romania, this conclusion is largely correct. The number of businesses required to report sustainability information has decreased significantly, and the direct pressure on SMEs has been substantially reduced.<\/p>\n\n\n\n
Following the amendments introduced through Directive (EU) 2026\/470, reporting obligations are now primarily concentrated on large companies that exceed specific thresholds\u2014more than 1,000 employees and more than EUR 450 million in turnover. In this context, entrepreneurs\u2019 skepticism is understandable. Many view the issue pragmatically: they need investments in business growth, production, and operational efficiency\u2014not ESG consulting, supplier data collection, or carbon footprint calculations.<\/strong><\/p>\n\n\n\n The problem is that this perception, while legitimate from a business perspective, overlooks an important shift: sustainability reporting obligations are not disappearing\u2014they are evolving. The relief is real, but only partial.<\/p>\n\n\n\n Who Remains Subject to Sustainability Reporting Obligations<\/strong><\/p>\n\n\n\n The Omnibus package has reduced direct pressure on small and medium-sized enterprises. The introduction of limitations on information requests to suppliers (the value-chain cap), together with the simplified voluntary VSME standard, means that many companies will no longer face complex formal reporting requirements.<\/p>\n\n\n\n However, large companies and listed entities remain subject to reporting obligations. Moreover, these obligations have not disappeared\u2014if anything, they have become more operationally challenging because companies must include information covering their entire value chain.<\/p>\n\n\n\n The challenge is that these companies do not directly control the data they need.<\/p>\n\n\n\n In many cases, their suppliers do not have ESG processes in place, do not collect sustainability data, lack defined indicators, and have little experience responding to such requests. As a result, the pressure is not eliminated\u2014it is redistributed throughout the value chain.<\/p>\n\n\n\n What the Legislation Actually Says<\/strong><\/p>\n\n\n\n Although the Omnibus package has reduced the number of companies required to publish sustainability reports, the obligation to incorporate value-chain information into the reporting process has not been removed.<\/p>\n\n\n\n Article 19a of the Corporate Sustainability Reporting Directive (CSRD) (EU) 2022\/2464 and the provisions of ESRS 1 \u2013 General Requirements explicitly require reporting entities to include in their assessment and reporting all relevant impacts, risks, and opportunities arising not only from their own operations but also from upstream and downstream value-chain relationships.<\/p>\n\n\n\n In other words, reporting is not limited to a company\u2019s direct activities. It also requires an assessment of suppliers, subcontractors, distributors, customers, and other relevant business partners.<\/p>\n\n\n\n At the same time, the Omnibus provisions relating to the value-chain cap limit the level of information that may be requested from SMEs within the value chain. For companies with fewer than 1,000 employees, requests should generally be limited to the information covered by the simplified voluntary VSME standard. However, all other suppliers with more than 1,000 employees may still be required to provide information aligned with the full ESRS standards, just as reporting entities subject to the CSRD must do.<\/p>\n\n\n\n This distinction is crucial. It demonstrates that many companies may leave the scope of direct reporting obligations but do not fully exit the CSRD ecosystem<\/strong>.<\/p>\n\n\n\n How the Obligation Spreads Through the Market<\/strong><\/p>\n\n\n\n This is where many companies still underestimate the scale of the change.<\/p>\n\n\n\n Large companies that remain subject to reporting requirements will begin requesting ESG information from their suppliers. Not because those suppliers have a direct legal obligation to report, but because without this data, large companies cannot adequately support their own reporting obligations.<\/p>\n\n\n\n As a result, pressure is transmitted through the market via commercial relationships, procurement procedures, supplier assessments, and contractual clauses.<\/p>\n\n\n\n \u201cA company that has no legal obligation to report may, in practice, find itself required to provide sustainability information in order to maintain commercial relationships with certain customers. And this is not limited to Romania. European value chains transmit this pressure across jurisdictions because reporting obligations apply to all companies operating within the European market and falling within the scope of the CSRD\u201d<\/em>, said Mihaela Silvia Croitoru<\/strong><\/a>, CEO of Sustainability Lens<\/strong>.<\/p>\n\n\n\n What Suppliers Need to Understand<\/strong><\/p>\n\n\n\n For many SMEs, the relevant question will no longer be, \u201cAre we legally required to report?\u201d but rather, \u201cCan we meet our customers\u2019 commercial requirements?\u201d<\/p>\n\n\n\n This will be particularly evident in sectors such as industrial manufacturing, automotive, FMCG, logistics, retail, construction, and others. The ability to provide basic sustainability information will gradually become a selection and evaluation criterion in establishing business relationships.<\/p>\n\n\n\n Companies that recognize this shift early and begin organizing their internal data, clarifying their processes, and responding to requests in a structured manner will gain a genuine competitive advantage.<\/p>\n\n\n\n By contrast, companies that treat such requests merely as an administrative formality may face difficulties in maintaining relationships with large customers or international groups of which they are part.<\/p>\n\n\n\n Conclusion<\/strong><\/p>\n\n\n\n \u201cOmnibus creates the impression of significant regulatory relief across the market. In reality, however, it changes the way sustainability reporting functions. The legal obligation remains concentrated among large companies, but its effects continue to spread throughout the entire value chain\u201d<\/em>, said Mihaela Silvia Croitoru<\/strong><\/a>, CEO of Sustainability Lens<\/strong>.<\/p>\n\n\n\n As a result, even companies that no longer have direct reporting obligations will increasingly become integrated into the CSRD framework through commercial relationships and requests from business partners. In other words, the CSRD may not create a direct legal obligation for a company, but it can create an indirect commercial obligation.<\/p>\n\n\n\n