Carbon footprint in 2026: who still needs one after Omnibus

Since the start of the year, the European sustainability reporting conversation has been dominated by a single idea: it has been simplified, so it no longer applies. The first half is true. The second is wrong, and expensive.

The Omnibus I Directive was adopted by the Council on 24 February 2026, published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. It raises the CSRD thresholds to companies with more than 1,000 employees and more than 450 million euro in net turnover, well above the previous thresholds. The amendments apply to financial years starting from 1 January 2027, with first reports in 2028. The number of ESRS datapoints was substantially reduced, while double materiality remained the founding principle for companies still in scope.

The result is that most companies in Romania have left the direct reporting obligation. They have not left the value chain of the companies that stayed in it.

Who is actually asking for your emissions data

In our practice, every carbon footprint request over the last twelve months came from one of four directions, and none of them was a direct legal obligation on our client.

Large customers. A staffing and HR services company received the request from a global technology client that needed the data for its own supplier sustainability platform. The calculation covered Scope 1, Scope 2 and Scope 3 categories 1 through 8. Without it, the commercial relationship became uncertain.

EcoVadis and supplier assessment questionnaires. The environment dimension is hard to improve without emissions data, and since May 2026 EcoVadis requires Scope 2 reported separately, location-based and market-based.

Banks and financial institutions, for financing files and for their own financed emissions reporting.

Tenders and procurement, public and corporate, where environmental criteria increasingly appear as an eligibility threshold rather than a bonus score.

In short, the legal obligation shrank while commercial demand grew. That is the opposite of what the market concluded.

What the value chain cap actually protects

An important element of the Omnibus package is the cap on the information that can be requested from smaller companies in the value chain. Companies within CSRD scope cannot require companies with 1,000 employees or fewer to provide more sustainability information than the voluntary reporting standard built on the VSME requires.

The nuance few people notice: Scope 3 emissions sit in the Comprehensive Module of the VSME, not the Basic Module. The cap therefore does not automatically shield you from a Scope 3 data request from a large customer.

The legal status of the delegated act setting this standard moved quickly through 2026 and is worth verifying as at the current date before building a position on it.

What a calculation that holds up looks like

The reference standard remains the GHG Protocol. The structure is familiar, but the difference between a usable calculation and one that fails first review sits in the details.

Scope 1 covers direct emissions: stationary combustion, mobile combustion, process emissions and fugitive refrigerant emissions. The most common error is ignoring refrigerant top ups, which are small in volume and large in impact.

Scope 2 covers purchased energy, reported on both methods. Each method needs its own documentation.

Scope 3 covers the fifteen value chain categories. Not all are relevant to everyone, and a properly executed relevance screening is worth more than a complete calculation done badly. For most service companies the weight sits in categories 1, 6 and 7. For manufacturers, in categories 1, 4 and sometimes 11.

Three methodological decisions make the difference under audit. The choice between spend based and physical activity data, with its justification. The definition of organisational and operational boundaries, particularly for groups with entities in several countries. The base year and recalculation rules, so that subsequent years remain comparable.

We have had projects where the discussion with the client's auditor came down to a single fuel price assumption and the tax basis used for it. The methodology document is what wins or loses that conversation.

What a properly run project delivers

A footprint calculation is only worth something if it stays usable after the consultant leaves. The deliverables that matter are the calculation file with visible formulas and emission factors identified by source and year, the methodology document explaining each choice, the relevance screening across the fifteen Scope 3 categories, intensity indicators enabling year on year comparison, and a clear list of missing data with how to collect it next year.

We ran one project across three consecutive years for an organisation with two centres, precisely so the sustainability report could show a trajectory rather than a snapshot. Without consistently calculated intensity indicators, a year on year comparison says nothing.

Autonomy or outsourcing

There are two reasonable ways to do this.

The first: the consultant performs the whole calculation. Faster, and appropriate when a customer or a tender has imposed a deadline.

The second: the consultant delivers the training, your team collects the data, and the consultant verifies that it was collected correctly and supports the calculation itself. Slower in year one and considerably cheaper from year two, because a carbon footprint is not a project but an annual exercise.

The choice is not about budget. It is about how often you will repeat the exercise. If you are asked annually, the second option pays for itself quickly.

Frequently asked questions

How long does a carbon footprint take? For Scope 1 and 2, four to six weeks depending on data quality. Including Scope 3, two to four months.

What data do I need to start? Energy, fuel and refrigerant consumption, the purchase ledger, business travel records and employee commuting information. Most of it already sits in accounting.

Does it need third party verification? Not mandatory, but verification raises credibility with large customers and is sometimes explicitly required in supplier questionnaires.

Can I use a free online calculator? For an internal estimate, yes. For a customer contractually requesting the data or for an assessment questionnaire, no, because you cannot document factors, boundaries and assumptions.

If someone has asked you for your carbon footprint and you do not know where to begin, start with what is actually being asked. Getting the scope right is the cheapest decision in the whole project.