The EU’s Corporate Sustainability Reporting Directive (CSRD) once looked set to pull thousands of companies — and their suppliers worldwide — into detailed sustainability disclosure. The 2025–2026 “Omnibus” simplification has changed that picture significantly. For Thai companies supplying European customers, the practical question is now narrower and clearer: what will your EU buyers actually ask you for?
What the Omnibus changed
The Omnibus I package sharply narrowed CSRD’s scope. Mandatory reporting now applies only to large undertakings with more than 1,000 employees and over €450 million in net turnover; listed SMEs are fully exempt. The timeline moved too — the simplified European Sustainability Reporting Standards (ESRS) are due around mid-2026, with mandatory reporting starting in 2028 on 2027 data, and optional early adoption in 2027.
Are Thai companies ever directly in scope?
Most are not — but large groups can be. A non-EU company is captured if it generates more than €450 million in net EU turnover and has an EU subsidiary or branch above defined thresholds. Thai multinationals with substantial European operations should check this directly. For everyone else, CSRD reaches you indirectly, through your EU customers’ value chains.
The value-chain cap: your most important protection
This is the change Thai suppliers should understand best. The Omnibus introduced a value-chain cap: a CSRD-reporting company cannot require a business in its value chain with 1,000 employees or fewer to provide more sustainability information than the dedicated voluntary standard (the VSME). In plain terms, your large European customer can no longer push its entire reporting burden down to you. If you are a smaller Thai supplier, what you can be compelled to give is limited — and EU buyers are explicitly told to request less than even the voluntary standard where they do not need it.
What to actually prepare
- Know your number. Whether you are directly in scope or responding to a customer, it starts with a credible GHG inventory and basic ESG data.
- Map your EU exposure. Identify which customers are CSRD reporters and what they are likely to ask under the capped, voluntary standard.
- Document in English. Whatever you provide is read, audited and consolidated in English. Inconsistencies between your Thai records and English submissions are the real risk — the same discipline that applies to CBAM data.
- Align it with your own disclosure. Responses to EU customers should match your sustainability report and any CSRD/ESRS work, so one set of numbers tells one story.
The Omnibus has made CSRD less of a blunt instrument and more of a targeted one. For Thai exporters and suppliers that is good news — but it does not remove the underlying need: clean ESG data, verified where it matters, documented accurately in both Thai and English. Othello International helps Thai companies prepare exactly that.
Related ESG guides
- CBAM in 2026: What Thai Exporters Must Do as the Definitive Phase Begins
- The 56-1 One Report ESG Section: What SET-Listed Companies Must Include (2026)
- IFRS S1 and S2 in Thailand: What SET-Listed Companies Must Disclose (2026)
- SET ESG Ratings Explained (2026): Criteria, Results, and the Shift to FTSE Russell
- Scope 1, 2 & 3 GHG Inventory for Thai Companies (TGO-Aligned)