For two years the message to transport companies was that CSRD was coming for them too. Then, on 18 March 2026, Directive (EU) 2026/470 entered into force. The Omnibus I package did the opposite of what almost everyone expected: it raised the thresholds instead of lowering them, taking roughly 80% of the newly captured companies back out of scope.
If you run a fleet in Italy, the odds that you are subject to CSRD reporting today are very low. That does not close the question, it moves it. It is no longer “do I have to report?” but “what can the customer who does have to report ask me for, and what am I obliged to hand over?”. Omnibus answered that precisely, and it is the part nobody talks about.
What Omnibus changed
CSRD now applies to companies that exceed both of these criteria:
- more than 1,000 employees on average over the financial year;
- more than €450 million in net revenue.
They are cumulative, not alternative. A company with 1,200 employees and €400M in revenue stays out; so does one with €500M in revenue and 800 employees. Before Omnibus the reference criteria were 250 employees and €40M, which explains the scale of the reduction.
Listed SMEs, which under the original design would have entered the obligation in 2026, are out entirely. For them reporting goes back to being voluntary.
Companies that remain above the thresholds report on financial years starting from 1 January 2027, with first publication in 2028. The attestation required is limited assurance, a limited-level review rather than a certification. Member States must transpose by 19 March 2027; in Italy that means amending Legislative Decree 125/2024.
Italy has brought part of this forward. Article 10 of Decree-Law 193 of 23 October 2026, in force since the 24th, adds a paragraph to Legislative Decree 125/2024: for financial years starting between 1 January 2026 and 31 December 2027, the decree does not apply to companies with net revenue up to €450 million or an average of up to 1,000 employees. Companies that were already reporting under the old thresholds are therefore exempt for 2026 and 2027 if they fall below either figure. The decree-law must be converted by 22 December 2026, and the text may still change.
What it means for an Italian fleet
The arithmetic is quick. An Italian haulier with 50 vehicles and around fifty staff sits at a twentieth of the headcount threshold, and on revenue is not even in the same order of magnitude. Even a structured logistics operator with a few hundred people and revenue in the hundreds of millions stays out until it clears both limits.
In Italian transport and logistics, above those thresholds you find the large groups and little else. Everyone else, which is very nearly the whole market, is in the opposite position: they do not report, but they sit in the value chain of somebody who does. That is where the data requests come from, and that is where Omnibus introduced a new rule.
The cap on what they can ask you for
If you are not in scope and stay below 1,000 employees, the directive classifies you as a protected undertaking within the value chain of an obligated company. A concrete right follows: you can refuse sustainability data requests that go beyond the scope of the voluntary VSME standard. Whoever makes the request must tell you the right exists, and cannot penalise you for exercising it.
This is the mechanism known as the value chain cap, and it is worth reading for what it is rather than as a general shield. Two qualifications.
First, the cap covers requests made for the purposes of reporting governed by the directive, not every ESG question. Obligations arising from other rules or other purposes stay outside it: a tender specification, a bank’s request, a clause you signed in a supply contract. Second, it applies from financial years starting 1 January 2027, so the first requests falling under the cap will arrive during that year.
What sits inside the VSME scope
VSME is the voluntary reporting standard EFRAG developed for non-listed companies outside the CSRD perimeter. It is modular, with a Basic and a Comprehensive module, and Omnibus makes it the benchmark for what an obligated customer can legitimately ask you. The Commission has identified which datapoints fall under the cap.
For a fleet it comes down to two families of data: energy consumption and greenhouse gas emissions. Nothing exotic, and precisely the point where most transport companies discover their data is the wrong shape, because what they hold is the fuel total off the invoice rather than litres per vehicle, estimated mileage rather than actual, and no separation between own vehicles and subcontracted trips.
Our seven-question check on which fleet data you actually hold tells you where you are starting from, before a customer asks and you are working to their deadline.
Scope 1, 2 and 3: where the fleet lands
The customer passing you the request thinks in the GHG Protocol’s three scopes, so it helps to know where you end up.
Scope 1 covers everything coming out of the exhaust of company vehicles: direct emissions, calculated from litres consumed times an emission factor. They are the easiest to reconstruct, provided you have consumption per vehicle and not just a period total.
Scope 2 covers purchased electricity, so it concerns fleets with electric vehicles and depends on the supplier’s energy mix. To know whether and how much it affects you, you first need a picture of what your fleet is made of.
Scope 3 is the one that explains why you got the request. It covers value chain emissions, and outsourced transport sits squarely inside it: if you deliver on behalf of an obligated customer, your emissions are their Scope 3. The same holds one rung down, for the owner-drivers and hauliers you subcontract to.
The calculation standard for transport
For this sector specifically the methodological reference is the GLEC Framework from the Smart Freight Centre, carried into the ISO 14083 standard, which defines how to calculate emissions per tonne-kilometre or per delivery, accounting for vehicle type and emission class, load factor, distance and route profile, and fuel or energy source.
One point deserves to be explicit, because our industry usually leaves it vague: Optivo does not certify ISO 14083 conformity and does not issue the report. What a fleet management platform does is produce and keep in order the underlying data the report needs, which is the part no consultant can reconstruct on your behalf. On what the standard actually requires we have a dedicated article on ISO 14083 for fleet operators.
What to have in place
The data a request inside the VSME scope will expect, and that is worth keeping ready:
- kilometres per vehicle, per period and per service type;
- actual fuel consumption, from telematics or fuel cards, not estimated from averages;
- vehicle classification by emission class and fuel type;
- load factor and utilisation rate;
- the perimeter of subcontracted trips, kept separate from those run with own vehicles.
Telematics systems collect most of these automatically. The source varies with the fleet: an OBD device on conventional vehicles, CAN bus integration on vehicles with factory telemetry, or the manufacturer’s cloud with no device on board for recent, natively connected vehicles, a route the EU Data Act made practical. The value is not in the collection but in the aggregation, that is, in turning thousands of daily data points into KPIs that are comparable over time.
For anyone keeping this on spreadsheets and fuel invoices the gap is real, but it is set-up work you do once.
Why to get ready without an obligation
The argument is not compliance, because for almost everyone there is no obligation. It is that the request arrives anyway, from three directions the value chain cap does not touch.
From customers, who have to close their Scope 3 and put transport data into tender specifications. From banks, which increasingly ask for a sustainability profile during credit assessment. And from tenders, where environmental criteria carry weight in the score and an answer built on an estimate loses to one built on a measurement.
In all three cases the gap between having the data and not having it cannot be closed in a fortnight. Those who have it answer; those who do not either pass or improvise, and it shows.
Frequently asked questions
Is my transport company subject to CSRD?
Almost certainly not. After Directive (EU) 2026/470 the obligation is triggered only by exceeding 1,000 employees and €450 million in net revenue together. In Italian transport and logistics that captures the large groups, not SMEs and not most structured operators either.
I am a listed SME and was told I had to report from 2026. Does that still hold?
No. Listed SMEs on regulated markets left the scope of the obligation with Omnibus. They can report voluntarily, typically under the VSME standard, but they are no longer subject to CSRD.
A customer is asking for very detailed ESG data. Can I refuse?
It depends why they are asking. If the request serves their sustainability reporting under the directive and you are below 1,000 employees, you can refuse the part that exceeds the VSME scope, and the customer is required to tell you that right exists. If the request comes from a tender specification, a contract clause you signed or another piece of legislation, the cap does not apply and what you signed governs.
When does the value chain cap take effect?
From financial years starting 1 January 2027.
What is the difference between CSRD and VSME?
CSRD is the legal obligation, with ESRS standards and an auditor’s attestation. VSME is EFRAG’s voluntary standard for companies outside that obligation, much lighter and split into a Basic and a Comprehensive module. Since Omnibus, VSME has a second function as well: it sets the limit on what an obligated company can ask of smaller suppliers.
Do fleet data need third-party certification?
The obligated company’s CSRD report requires limited assurance on the report itself, not certification of individual suppliers’ data. What you need is to be able to document where every number you hand over comes from: source, period, calculation method.
Next step
If a customer has already asked you for transport data, or you expect them to in 2027, the time to find out what data you actually hold is now, not when the request lands. Book a 20-minute call with an Optivo specialist: we look at what your fleet produces today and what is missing to answer without estimating.