{"id":3131,"date":"2026-06-18T16:17:42","date_gmt":"2026-06-18T16:17:42","guid":{"rendered":"https:\/\/auditcloud.ma\/?p=3131"},"modified":"2026-06-18T17:34:03","modified_gmt":"2026-06-18T17:34:03","slug":"3131","status":"publish","type":"post","link":"https:\/\/auditcloud.ma\/en\/2026\/06\/18\/3131\/","title":{"rendered":"CSRD and Moroccan companies: presentation and post-Omnibus impacts"},"content":{"rendered":"<div class=\"ac-csrd-article\">\n<header class=\"ac-hero\">\n<div class=\"ac-opening-quote\">Is Brussels backtracking on sustainability? It&#039;s an appealing interpretation. It&#039;s also an analytical error that could prove costly.<\/div>\n<p class=\"ac-lead\">With the Omnibus Directive, the European Union has effectively reduced by nearly <strong>80 %<\/strong> the number of companies directly subject to the CSRD. But to conclude that the obligation disappears is to confuse the legal scope with economic reality.<\/p>\n<\/header>\n<section class=\"ac-section\">\n<h2 class=\"ac-section-title\"><span class=\"ac-number\">1. <\/span>What are we talking about?<\/h2>\n<p>The CSRD (<em>Corporate Sustainability Reporting Directive<\/em>) is the European directive that governs the publication of sustainability information by companies.<\/p>\n<p>It does not simply require communication on CSR. It mandates standardized, structured, and third-party verified sustainability reporting, on par with financial information, based on three principles:<\/p>\n<ul>\n<li>common standards, the ESRS standards, so that data is comparable from one company to another; ;<\/li>\n<li>the dual materiality: to account for both the impact of sustainability on financial performance, and the impact of the activity on the environment and society;<\/li>\n<li>mandatory verification of published information.<\/li>\n<\/ul>\n<p>It is this last point that changes everything: with the CSRD, extra-financial data moves from the realm of communication to that of audited data.<\/p>\n<p>In its initial version, the measure was intended to extend the obligation to more than <strong>50,000 companies<\/strong> in Europe, compared to approximately <strong>11 700<\/strong> under the old NFRD directive. It is this ambition that the Omnibus has come to recalibrate.<\/p>\n<p>&nbsp;<\/p>\n<\/section>\n<section class=\"ac-section\">\n<h2 class=\"ac-section-title\"><span class=\"ac-number\">2. <\/span>What the Omnibus has changed in 2026<\/h2>\n<p>Approved by the European Parliament on 16 December 2025, definitively adopted by the Council on 24 February 2026, the Omnibus Directive was published in the Official Journal of the European Union on 26 February 2026 and entered into force on 18 March 2026.<\/p>\n<p>Its stated objective: to simplify and reduce the regulatory burden. In concrete terms, three major changes.<\/p>\n<h3>A significantly narrowed scope<\/h3>\n<p>Previously, a company was affected as soon as it exceeded two of three criteria: 250 employees, 40 million euros in turnover, 20 million euros in total assets.<\/p>\n<p>From now on, the criteria become cumulative and significantly more stringent:<\/p>\n<ul>\n<li><strong>more than 1,000 employees; ;<\/strong><\/li>\n<li><strong>and more than 450 million euros in net sales.<\/strong><\/li>\n<\/ul>\n<p>The balance sheet total criterion is removed. As a result, almost all listed SMEs are excluded from the scope, and the scheme focuses on large groups.<\/p>\n<figure class=\"ac-figure\"><img decoding=\"async\" src=\"https:\/\/auditcloud.ma\/wp-content\/uploads\/2026\/06\/Shema-1.png\" alt=\"Ce que l\u2019Omnibus a chang\u00e9 : champ d\u2019application de la CSRD avant et apr\u00e8s mars 2026\" \/><\/figure>\n<h3>A postponed schedule<\/h3>\n<p>The first publications, for companies newly in the field, are expected in 2028, for the 2027 financial year. Companies that were due to start in the 2024 financial year also benefit from a transitional exemption.<\/p>\n<figure class=\"ac-figure\"><img decoding=\"async\" src=\"https:\/\/auditcloud.ma\/wp-content\/uploads\/2026\/06\/Shema-2.png\" alt=\"Calendrier post-Omnibus des \u00e9tapes cl\u00e9s du nouveau dispositif de reporting de durabilit\u00e9\" \/><\/figure>\n<h3>A reduced duty of vigilance\u2026 but still maintained<\/h3>\n<p>The duty of vigilance component (CS3D) now only applies to groups of more than <strong>5,000 employees<\/strong> realizing <strong>1.5 billion euros in global revenue<\/strong>, with a methodology refocused on risks and the elimination of the mandatory climate transition plan.<\/p>\n<p>At first glance, then, a clear sense of relief. Except that this relief is largely an optical illusion.<\/p>\n<p><span style=\"font-family: Montserrat; font-size: 2em; font-weight: 800; letter-spacing: -1px;\">3. <\/span><span style=\"font-family: Montserrat; font-size: 2em; font-weight: 800; letter-spacing: -1px;\">The illusion of relief: being outside the legal framework is not the same as being out of the game<\/span><\/p>\n<\/section>\n<section class=\"ac-section\">Here&#039;s the point that many analyses miss. The Omnibus Directive reduces the number of companies directly subject to it. But it maintains\u2014and even reinforces\u2014the value chain logic. Large groups that remain within its scope must now report on sustainability risks across their entire value chain, and not just to their primary partners. To produce this report, they need one thing: data from their suppliers and subsidiaries. However, be careful not to misunderstand: a Moroccan supplier does not automatically become subject to the CSRD (Sustainability Risk Assessment). The legal obligation remains with the multinational corporation. What flows down the value chain is not an obligation in the strict sense, but a structured commercial requirement: the large group asks its partners for the data it needs for its own reporting.<\/p>\n<p>And this requirement is itself regulated. Since the Omnibus, a value chain ceiling (<em>value-chain cap<\/em>This protects smaller businesses: a large group cannot demand more information from a partner with fewer than 1,000 employees than what is required by the applicable voluntary standard. The supplier is therefore not bound by the directive\u2014but its European client is, and will, in this context, favor partners capable of providing reliable data.<\/p>\n<p>To regulate these exchanges, the European Union is preparing a voluntary sustainability standard for SMEs (VSME), based on the framework developed by EFRAG, whose delegated act is expected in June 2026. This standard will play a dual role: it will provide a common language for the demands of contracting authorities, but above all, it will serve as a ceiling \u2014 the famous <em>value-chain cap<\/em> \u2014 beyond which a large company cannot demand information from a partner outside its scope. In other words, it protects as much as it structures.<\/p>\n<div class=\"ac-quote\">The question for a Moroccan company is therefore not: am I subject to the CSRD? It is: are my European clients subject to it, and what will they ask of me?<\/div>\n<figure class=\"ac-figure\"><img decoding=\"async\" src=\"https:\/\/auditcloud.ma\/wp-content\/uploads\/2026\/06\/Shema-3.png\" alt=\"Effet de cascade : de l\u2019obligation l\u00e9gale de la multinationale \u00e0 l\u2019exigence commerciale envers les filiales et fournisseurs marocains\" \/><\/figure>\n<\/section>\n<section class=\"ac-section\">\n<h2 class=\"ac-section-title\"><span class=\"ac-number\">4. <\/span>Why Morocco is on the front line<\/h2>\n<p>This is where the subject ceases to be theoretical for Moroccan companies.<\/p>\n<p>Morocco is now one of the most integrated partners in European industry. A few key indicators are enough to demonstrate this.<\/p>\n<p>According to the Exchange Office, <strong>The automotive sector is the Kingdom&#039;s leading export sector, with exports projected at 154.5 billion dirhams in 2025.<\/strong>, in the order of 14 to 15 billion euros. However <strong>90% of Moroccan automobile production is exported, of which more than 80% go to Europe.<\/strong>, and the sector relies on a network of <strong>more than 260 equipment manufacturers and suppliers.<\/strong><\/p>\n<p>These equipment suppliers provide equipment to manufacturers like Renault Tanger or Stellantis K\u00e9nitra \u2014 exactly the type of multinationals that remain in the field of CSRD after Omnibus.<\/p>\n<p>The reasoning applies beyond the automotive sector. Aeronautics, textiles, agri-food and phosphates and derivatives, with 99.8 billion dirhams in 2025, or about 9 to 10 billion euros, according to the Exchange Office, all rely, to varying degrees, on European clients subject to sustainability reporting.<\/p>\n<div class=\"ac-example\">\n<pre class=\"ac-example-title\"><em><strong>Example:<\/strong><\/em>\r\n\r\nAn automotive supplier located near Tangier, which supplies a major European manufacturer, is not directly targeted by the CSRD (Committee for the Social and Solidarity Economy). However, its client is required to document the environmental and social footprint of its supply chain. Specifically, this Moroccan supplier will receive an ESG questionnaire covering energy consumption, emissions, working conditions, purchasing policies, and governance.\r\n\r\n<em>If it can answer these questions with reliable and documented data, it becomes a preferred supplier.<\/em>\r\n<em>If he doesn&#039;t know, he becomes a risk \u2014 and a risk eventually gets replaced.<\/em>\r\n\r\n<strong>For him, sustainability is no longer a matter of image. It has become a condition for market access.<\/strong><\/pre>\n<\/div>\n<\/section>\n<section class=\"ac-section\">\n<h2 class=\"ac-section-title\"><span class=\"ac-number\">5. <\/span>The Moroccan groups directly concerned<\/h2>\n<p>Beyond the cascading effect, some large Moroccan groups are directly entering the field.<\/p>\n<p>The directive stipulates that companies from third countries are concerned when:<\/p>\n<ul>\n<li>their parent company achieves more than <strong>450 million euros<\/strong> of net turnover in the EU; ;<\/li>\n<li>and that their European subsidiary or branch exceeds <strong>200 million euros<\/strong>.<\/li>\n<\/ul>\n<p>Major Moroccan exporters, as well as industrial and financial groups with significant operations in Europe, must therefore carefully assess their situation. For them, sustainability reporting is not a distant prospect: it is an obligation that must be addressed immediately.<\/p>\n<figure class=\"ac-figure\"><img decoding=\"async\" src=\"https:\/\/auditcloud.ma\/wp-content\/uploads\/2026\/06\/Shema-4.png\" alt=\"Trois fa\u00e7ons d\u2019\u00eatre concern\u00e9 par la CSRD : filiale, fournisseur ou groupe marocain pr\u00e9sent en Union europ\u00e9enne\" \/><\/figure>\n<\/section>\n<section class=\"ac-section\">\n<h2 class=\"ac-section-title\"><span class=\"ac-number\">6. <\/span>The real issue isn&#039;t reporting. It&#039;s data.<\/h2>\n<p>If we take a step back, the Omnibus did not eliminate the CSRD. It simply shifted the playing field.<\/p>\n<p>We have moved from the question of who should publish? to a much more demanding question: what data is reliable enough to be consolidated, verified and, where appropriate, audited?<\/p>\n<p>And that&#039;s a considerable change in nature.<\/p>\n<p>As long as sustainability was a matter of communication, a statement was a commitment. Now, a statement is only valid if it is measured, documented, and traceable. ESG data enters a consolidated sustainability statement just like an entry enters into the accounts: with an audit trail, a methodology, and assurance of reliability.<\/p>\n<p>This is precisely where the value of an audit and accounting firm lies. Where a communications consultant produces a speech, the chartered accountant produces defensible data \u2014 data that will withstand the questionnaire of a client, the examination of an auditor, or the consolidation of a parent company.<\/p>\n<p>Paradoxically, by concentrating the obligation on the most exposed actors and circulating it through data, the Omnibus increases the value of accounting expertise. It does not reduce it.<\/p>\n<\/section>\n<section class=\"ac-section\">\n<h2 class=\"ac-section-title\"><span class=\"ac-number\">7. <\/span>What should Moroccan companies do, starting now?<\/h2>\n<p>Four simple reflexes can transform a constraint into an advantage:<\/p>\n<ol>\n<li><strong>Mapping your exhibition<\/strong> \u2014 Are my clients or my parent company subject to the CSRD or the duty of vigilance? Am I in a relevant value chain?<\/li>\n<li><strong>Making your data reliable<\/strong> \u2014 energy, emissions, social, governance: have measured and documented figures, not estimates.<\/li>\n<li><strong>Preparing for the questionnaire<\/strong> \u2014 anticipate the demands of clients rather than discover them, based on the future VSME framework.<\/li>\n<li><strong>Structuring an auditable approach<\/strong> \u2014 to build an audit trail for non-financial data, to make it a commercial argument and not a weakness.<\/li>\n<\/ol>\n<\/section>\n<section class=\"ac-cta\">\n<h2>We can assist you<\/h2>\n<p>In practice, the main challenge for a Moroccan company is not to achieve sustainability.<\/p>\n<p>The real challenge is producing reliable, documented, and defensible data that meets the requirements of its European clients and financial partners. This is precisely AuditCloud Morocco&#039;s business. We support companies across the entire value chain, including:<\/p>\n<ul>\n<li>CSRD exposure diagnosis and CS3D duty of vigilance, for subsidiaries as well as suppliers; ;<\/li>\n<li>direct eligibility analysis for Moroccan groups established in Europe, criteria of \u20ac450\/\u20ac200M; ;<\/li>\n<li>structuring and ensuring the reliability of ESG data, with the implementation of an audit trail; ;<\/li>\n<li>preparation for client requests and the VSME standard.<\/li>\n<\/ul>\n<p>The goal is not to produce yet another report. It is to build a data point:<\/p>\n<div class=\"ac-tags\">\n<div class=\"ac-tag\"><strong>Reliable<\/strong><br \/>\nbecause it is measured and plotted<\/div>\n<div class=\"ac-tag\"><strong>Compliant<\/strong><br \/>\nbecause it is aligned with European requirements<\/div>\n<div class=\"ac-tag\"><strong>Strategic<\/strong><br \/>\nbecause it now conditions access to markets and financing<\/div>\n<\/div>\n<p><strong>Because the real question, after the Omnibus, is no longer whether sustainability is mandatory.<\/strong><\/p>\n<p>It&#039;s about knowing whether your data is robust enough to open doors for you \u2014 or fragile enough to close them.<\/p>\n<\/section>\n<\/div>","protected":false},"excerpt":{"rendered":"<p>Bruxelles fait marche arri\u00e8re sur la durabilit\u00e9 ? C\u2019est une lecture s\u00e9duisante. C\u2019est aussi une erreur d\u2019analyse qui peut co\u00fbter cher. Avec la directive Omnibus, l\u2019Union europ\u00e9enne a effectivement r\u00e9duit de pr\u00e8s de 80 % le nombre d\u2019entreprises directement soumises \u00e0 la CSRD. Mais conclure que l\u2019obligation dispara\u00eet, c\u2019est confondre le p\u00e9rim\u00e8tre l\u00e9gal et la [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":3144,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[6],"tags":[],"class_list":["post-3131","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-fiscalite"],"_links":{"self":[{"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/posts\/3131","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/comments?post=3131"}],"version-history":[{"count":15,"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/posts\/3131\/revisions"}],"predecessor-version":[{"id":3148,"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/posts\/3131\/revisions\/3148"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/media\/3144"}],"wp:attachment":[{"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/media?parent=3131"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/categories?post=3131"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/auditcloud.ma\/en\/wp-json\/wp\/v2\/tags?post=3131"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}