Sustainability reporting officially narrowed: who still has the obligation and what rights suppliers gain

In shortOn 13 October the Ministry of Finance published, in Official Gazette no. 858, Order no. 1.281/2026, which transposes into Romanian law the European "Omnibus" directive on simplifying sustainability reporting. The obligation remains only for companies with more than 1,000 employees AND net turnover above RON 2.25 billion - both conditions at the same time. Companies that had entered the calendar for the 2025-2026 financial years can be exempted, and small suppliers receive, for the first time, a legal right to refuse excessive ESG questionnaires.

New thresholds, new calendar

Until now, the calendar approved by Order no. 85/2024 was gradually bringing thousands of large Romanian companies into sustainability reporting. Order no. 1.281/2026 changes the basic rule: only entities that exceed, at the same time, an average of 1,000 employees and a net turnover of RON 2.25 billion (the equivalent of the European threshold of €450 million) report. The same thresholds apply to parent companies, on a consolidated basis.

The first reports under the new rules are drawn up for financial years starting on 1 January 2027, and for certain categories from 1 January 2028. Just as important for the present: entities that had come under the obligation under the old rules can be exempted for financial years starting between 1 January 2025 and 31 December 2026 if they do not exceed the new thresholds. In other words, many companies now working on their 2026 report can stop the clock - legally.

Out of the obligation? The market still asks you for data

The legal exemption does not stop commercial requests. Retailers, banks and corporate customers keep asking for sustainability data - through EcoVadis, CDP or their own questionnaires. The reference for these answers becomes the voluntary VSME standard, designed precisely for companies outside the obligation. The work done so far is not lost: data collected for ESRS converts, with little effort, into a VSME report that answers all requests from a single source.

The shield for suppliers: what you can refuse from now on

The novelty with immediate effect in commercial relationships: suppliers with at most 1,000 employees in the value chain of a reporting company may refuse to provide information exceeding the voluntary standards. Customers cannot impose the opposite by contract, and if they still ask for more they must state explicitly that the supplier has the right to refuse. The reporting company may accept a supplier's self-declaration and has a three-year transition in which it can explain missing data and use estimates.

Key points:

The two thresholds are cumulative: below either of them, the reporting obligation disappears - including, through the exemption, for the 2025 and 2026 financial years already under way.
Leaving the obligation does not mean the requests disappear: banks and retailers keep asking for data, and VSME becomes the common language of the answers.
Suppliers with at most 1,000 employees may legally refuse questionnaires that exceed the voluntary standard - check what you sign in commercial contracts.

Legal basis: Order no. 1.281/2026 of the Minister of Finance on simplifying sustainability reporting (Official Gazette no. 858 of 13 October 2026); Directive (EU) 2026/470 ("Omnibus I"); Order no. 85/2024 of the Ministry of Finance and the Accounting Regulations approved by Order no. 1.802/2014, as amended; Directive (EU) 2022/2464 (CSRD).

What we do

Circulad'OR can tell you, in a single conversation, where you stand against the new thresholds and what remains to be done - mandatory reporting, voluntary VSME reporting or just targeted answers to customers and banks. For companies choosing the voluntary route, we prepare the transition to VSME, and the upcoming Yvora CSRD Suite will turn data collection into a process that runs by itself, not an annual chore. Write to us.