Omnibus I: what the directive actually changed for Swiss companies.

Press summaries called it a CSRD pull-back. The directive itself reshaped thresholds, postponed waves, and made limited assurance permanent. This note walks the actual articles, then names what did not change for Swiss companies.

Draft. Body to be written by Frédéric. The structure, audience, and source list are defined in investor-data-room/NOTES-OUTLINES.md. Every factual claim must trace to a primary source cited in-line — Directive (EU) 2026/470 articles by number.

The shape of the note

Audience: a founder, accountant, or banker who has read press summaries about Omnibus I and wants the source of truth.

Goal: cut through the post-Omnibus confusion with a primary-source walk-through.

  • Lede: the friends-and-family feedback line that surfaced this — "the thesis was written for a regulatory world that stopped existing six weeks before."
  • What Omnibus I changed: thresholds raised to >1,000 employees AND >€450M turnover; Wave 2 reporting postponed to FY2027 (first publish 2028); reasonable-assurance transition removed, limited assurance permanent; value-chain information requests capped at VSME scope for suppliers under 1,000 FTE.
  • What did not change for Swiss companies: Swiss CO Art. 964a-c still applies to large Swiss companies; VSME demand from EU customers still lands; FINMA expectations cascade onto Swiss banks' SME clients.
  • Honest count: how many Swiss companies are mandatorily affected now — order of magnitude, sourced.
  • What the post-Omnibus voluntary market actually looks like, without speculation, with sourced numbers.
  • One paragraph on what cobank concluded: voluntary corporate is primary, enterprise long-term, audit-firm partnership the ultimate target.