Starting March 19, 2026, the Omnibus Directive (EU) 2026/XXX, which simplifies[1] reporting requirements under CSRD and CSDDD comes into effect. Companies in the so-called Wave 1, already reporting for 2024, received a 2-year relief for 2025–2026[2], while Wave 2 companies – large EU and international firms employing at least 1000 workers – will start reporting only for 2027 (publication in 2028). The package reduces mandatory data points in ESRS by around 60%, but maintains the double materiality requirement and auditing under a limited assurance framework. Polish Wave 2 companies, exceeding the thresholds of 1000 employees and 450 million EUR turnover, gain an extra year for implementation but must complete double materiality assessment and gap analysis by the end of 2026, as well as prepare for mandatory XBRL tagging in ESEF format.
CSRD Omnibus and ESG Rating Regime
At the same time, the European Union is tightening oversight on ESG ratings. Starting July 2026, the Regulation on Transparency and Integrity of ESG Rating Activities, which requires[14] rating agencies to obtain ESMA authorization and disclose applied methodologies, will apply. This concerns global entities such as MSCI, Sustainalytics, ISS ESG, Moody’s ESG, and S&P Global ESG, whose ratings affect capital costs, ESG fund accessibility, and green bond issuances. In February 2026, MSCI updated its model[27], changing the ratings of 37% of companies, of which 26% changed solely due to methodological causes. Parallel consultations of similar regulations are being conducted by the UK regulator FCA, planning its own authorization system from June 2027.
Germany and Hydrogen as a Model for Poland
On March 15, 2026, the European Commission approved a payment of 4.6 billion EUR[6] from the Recovery and Resilience Facility to Germany following the achievement of 22 milestones, including targets for hydrogen projects. This is the first full RRF tranche for hydrogen achievements and a significant precedent for other countries, including Poland. Concurrently, the German government launched an industry decarbonization program worth about 6 billion EUR[7], covering technologies like CCS with auctions planned from mid-2026, and is using the third auction of the European Hydrogen Bank with a budget of 1.3 billion EUR. For Warsaw, this signals that rapid milestone achievement in renewables, energy efficiency, and hydrogen can unlock its own RRF funds and enhance the competitiveness of domestic projects applying to the EU Innovation Fund.
Acceleration of Renewables in Poland and Offshore Auctions
Poland is concluding a revolution in national legal frameworks[10] for renewable energy. On March 11, 2026, an amendment to wind investment law from June 2025 came into force, abolishing long-standing locational restrictions, including the “10H” rule that blocked onshore wind farm development. The government under Donald Tusk and the Ministry of Climate are introducing incentives for hybrid projects (wind + photovoltaics + BESS energy storage) and for biogas plants and biomethane installations, while Polish Power Grid is testing cable pooling and hybrid projects from 2025. These changes, supported by the Deregulation Program from March 2025, could quickly increase renewables’ share in the national energy mix and reduce coal dependency, while benefiting from a growing yet relatively stable green bond market valued at 800–900 billion dollars annually. On the horizon are foreign benchmarks: in the UK, the Department for Energy Security and Net Zero announced the launch in July 2026 of the CfD Allocation Round 8, expected to be the largest offshore wind auction in Europe following the record AR7 round, serving as a reference point for Polish projects in the Baltic Sea.
Urban Mining, Batteries, and CCS
Significant signals also come from critical raw materials and recycling. In the Netherlands, Stichting OPEN revealed that households store around 7 billion kg[22] of electrical devices, of which 764 million kg are such as copper, aluminum, neodymium, and cobalt. The findings are based on the methodology of the consortium Futu. RaM which studied urban mines across the EU[11], illustrating the potential to significantly decrease dependency on non-European suppliers under the Critical Raw Materials Act. Concurrently, the Battery Recycling Europe conference in London showed that by 2031 EU battery regulations will require at least 16% cobalt, 6% lithium, and 6% nickel in electric vehicle batteries to come from recycling, increasing to 26%, 12%, and 15% respectively by 2036. Manufacturers like CATL, LG, Samsung, and Northvolt, together with recyclers such as Accurec and Umicore, are preparing for full traceability of batteries through Digital Battery Passports, which will become mandatory from 2026.
CBAM and New Regulatory Risks
Against this backdrop, the landscape of climate policy and border regulations is also shifting. The Carbon Border Adjustment Mechanism has entered its definitive phase[26] after a two-year transition, obliging importers of at least 50 tons of cement, steel, aluminum, fertilizers, electricity, and hydrogen to purchase CBAM certificates at prices close to the average EU ETS auction level, currently around EUR 85–95 per ton of CO2. The first full declarations from importers will be submitted on July 1, 2027, while sales of certificates were postponed to February 1, 2027[28], giving firms additional time to prepare carbon footprint data for supply chains, especially imports from Russia, Ukraine, Belarus, and Turkey. Concurrently, other regulations come into force, such as the greenwashing directive with penalties up to 4% of turnover from September 27, 2026, the EUDR regulation with a final compliance deadline on December 30, 2026 for large companies, and evolving CCS infrastructure across Europe, where projects like Brevik–Northern Lights in Norway and UK’s Hy. Net and Teesside are crucial for energy-intensive sectors facing rising ETS and CBAM costs.
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Related posts:
- EU Taxonomy Consultations, First CBAM Price, and Energy Price Pressure — A Week in ESG
- CBAM, the Hamburg Declaration, and CSRD Adjustment: A Breakthrough Week in Global ESG
- ESG at a Crossroads: CBAM, Simplified Reporting, and Real Costs of the Climate Crisis
- USA Loosen CO₂ Emission Controls, EU Strengthens Climate Tools, Poland Accelerates in Renewables