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48 SMT007 MAGAZINE I MARCH 2026 tronics Association has tools available for the elec- tronics industry to complete their DMA. On Oct. 17, 2025, the Omnibus amendment to the CBAM Regulation was published in the EU Official Journal as Regulation (EU) 2025/2083. Following the publication of key implementing and delegated acts on Dec. 17, 2025, CBAM compliance is now entering its definitive phase. Scope of the CSRD The Omnibus Directive significantly narrows the CSRD scope: Only large undertakings with more than 1,000 employees and a net annual turnover exceeding €450 million are required to report. Listed Small and Medium-sized Enterprises (SMEs) are exempt, which marks a substantial shift from the original legal framework. Other changes include (see also Figure 3): • Scope for third-country companies: Non-EU undertakings generating €450 million net annual turnover in the EU (individually or on a consolidated basis) for each of the last two consecutive years, and having a subsidiary or a branch in the EU exceeding €200 million net turnover • Value chain cap: Safeguards have been introduced for companies in the value chain that fall below the threshold of 1,000 employ- ees; the information requests are limited to the information included in the voluntary sus- tainability reporting standard • Permitted information omission: Companies may omit certain information, such as com- mercially sensitive, classified, or IP-related information if certain conditions are met • Voluntary sustainability reporting standards (VSME): The EC will adopt VSME for under- takings with under 1000 employees • Sustainability assurance: Limited assurance remains mandatory, with a limited assurance standard to be adopted by July 1, 2027 • Digital support: The EC will establish a one- stop-shop portal with information, guidance, and support, including templates, linked to sustainability reporting Change to the CSDDD Substantial changes have been introduced to the CSDDD. Member States must transpose the Direc- tive by July 26, 2028. The amended rules will apply from July 26, 2029, while the obligation for in-scope companies to publish on their website an annual statement on sustainability due diligence matters will apply to financial years starting on or after Jan. 1, 2030. • Narrowed scope: The scope of the CSDDD is narrowed by higher applicability thresholds. The Directive applies to EU companies with more than 5,000 employees and a net world- wide turnover exceeding EUR 1.5 billion, and to non-EU companies generating more than EUR 1.5 billion in turnover within the EU. • Amended due diligence framework: The risk-based due diligence approach is retained, with modified operational require- ments. Companies must conduct a scoping exercise based on reasonably available infor- mation to identify areas across their oper- ations, subsidiaries, and relevant business partners where adverse impacts are most likely and most severe. In-depth assessments are limited to these. Information requests to business partners are restricted to the neces- sary, with additional safeguards for partners with fewer than 5,000 employees. • Changes to penalties and civil liability: Pen- alties for non-compliance are limited to a " The Omnibus Directive significantly narrows the CSRD scope: Only large undertakings with more than 1,000 employees and a net annual turnover exceeding €450 million are required to report."