Key development
On 27 March 2026, the Council of Ministers approved a preliminary draft bill aimed at partially transposing the Omnibus I Directive into Belgian law (see here). The bill introduces an exemption from sustainability reporting for certain “first wave” companies.
Background: the “Stop-the-Clock” Directive and the three waves
The “Stop-the-Clock” Directive introduced a two-year postponement of CSRD obligations for the second and third waves of companies (see our previous article). However, the first wave – large public-interest entities with more than 500 employees – continued to be subject to reporting obligations under the CSRD.
The Omnibus I Directive changes this by providing that the first wave companies falling below either of the following thresholds will be exempt from sustainability reporting as of the 2027 financial year:
- net turnover of less than EUR 450 million; or
- an average of fewer than 1,000 employees.
Importantly, Article 3(1)(c) of the Omnibus I Directive grants Member States the option already to apply this exemption as of the 2025 financial year.
Belgium’s approach: early opt-in
The Council of Ministers has chosen to exercise this option, albeit not at the earliest possible date of 2025. In practice, the relevant companies will no longer be required to prepare and disclose sustainability information for the 2026 financial year onwards.
Next steps
The preliminary draft bill has been submitted to the Council of State for an advisory opinion. Once the opinion is issued, the preliminary draft may be amended and will then be submitted to Parliament, where it must go through the remaining stages of the legislative process.
The remaining provisions of the Omnibus I Directive must be transposed into national law by 19 March 2027 at the latest, with the exception of the provisions relating to the CSDDD, for which the transposition deadline runs until 26 July 2028.
Practical takeaway
First wave companies falling below one of the thresholds should monitor the progress of this draft bill closely. If it is enacted, they will benefit from an early exemption, covering the 2026 financial year.
For more details on the Omnibus I Directive, please consult our substantive discussion.
