October 19, 2026

ESG in Bulgaria after the Omnibus: A Lighter Reporting Landscape

Тhe Omnibus has reduced mandatory ESG reporting obligations for most Bulgarian companies and mandatory reporting is now unlikely to apply for them

‍The Omnibus is now law

Directive (EU) 2026/470 entered into force on 18 March 2026. Bulgaria must transpose the Corporate Sustainability Reporting Directive (CSRD) by 19 March 2027 and the Corporate Sustainability Due Diligence Directive (CSDDD) by 26 July 2028.

What changed for CSRD?

  • ‍Scope: Companies must now meet both of the following: more than 1,000 employees and more than €450 million in net annual turnover. This is stricter than the original CSRD threshold.‍
  • Timing: In-scope EU companies must report for financial years starting on or after 1 January 2027, with first reports due in 2028. Companies previously in scope under Wave 1 that no longer meet the revised thresholds may benefit from a transitional exemption for financial years 2025 and 2026, subject to national implementation.‍
  • Reporting standards: The simplified European Sustainability Reporting Standards (ESRS) process has advanced. EFRAG submitted its technical advice to the Commission in December 2025, and the Commission adopted and published the relevant delegated acts in July 2026.‍
  • Value chain cap: Companies may not request ESG data from supply chain partners with up to  1,000 employees beyond what voluntary reporting standard permits, subject to the exceptions in the Omnibus framework.

What changed for CSDDD?

  • ‍Scope: The final thresholds are more than 5,000 employees and more than €1.5 billion in net annual  turnover. Both conditions must be met. The scope has been narrowed  significantly, and it covers under one fifth of the companies originally  intended.‍
  • Timing: Companies must comply by July 2029. Member States must transpose by 26 July 2028.‍
  • Due diligence approach: The process is now explicitly risk-based. Companies may conduct an initial scoping based on reasonably available information to identify where adverse impacts are most likely to occur, rather than a mandatory across-the-board assessment.‍
  • Civil liability: The EU-wide harmonised civil liability regime has been removed. Liability for due diligence failures reverts to national law.‍
  • Director liability: The CSDDD Union-wide liability regime has been removed. National corporate, tort, administrative, or other laws may still impose director-level liability outside the CSDDD framework.‍
  • Climate transition plan: The CSDDD obligation to adopt and implement a transition plan has been removed. CSRD/ESRS reporting can still require in-scope reporting undertakings to disclose information about transition plans and related implementation actions, not merely where a plan already exists.‍
  • Penalties: Capped at 3% of worldwide net turnover.

What This Means for  Bulgarian Companies?

Mandatory reporting will apply to fewer companies. Bulgaria adopted its ESG reporting framework in August 2024 through amendments to the Accounting Act. In early 2026, the National Assembly postponed the first reporting period by one year. With the Omnibus thresholds now confirmed, only a small number of Bulgarian companies are likely to remain in mandatory CSRD scope, mainly among the largest enterprises.

National implementation still matters. Bulgaria must transpose the Omnibus by March 2027. Companies that were preparing for reporting obligations under the original framework should follow the transposition process closely, as certain implementation choices remain for the national legislature.

One point should not be overlooked. ESG  expectations and green-claims risk remain. For many Bulgarian companies, mandatory sustainability reporting is now less likely to apply. That does not mean ESG risk has receded. It has shifted into financing conditions, supply-chain expectations, M&A due diligence, and the legal scrutiny of public sustainability claims.

The Omnibus reduces mandatory reporting, but it does not reduce ESG-related demands from clients, banks, investors, procurement, or supply chains. Nor does it affect what companies may publicly say about their sustainability performance. Public sustainability claims are governed by a separate consumer-protection framework, which is tightening independently.

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Ana-Mari Eremieva
Senior Associate

Ana-Mari is noted for her responsibility and relentless pursuit of high-quality service, consistently aligning her work with clients' business needs

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