Background to the EU Omnibus Initiative

On 26 February 2025 the EU Commission launched an initiative to ease the burden on companies facing myriad reporting obligations – such as from the CSRD, CSDDD oder der EU-Taxonomie. The main focus is on reducing duplicate content and simplifying the requirements, with the ultimate aim to strengthen competitiveness and shrink the administrative workload.

Contents of the Omnibus package

The Omnibus package incorporates several proposals of relevance for sustainability reporting: 

• Proposal I: Adjustment of thresholds, content and due diligence obligations 
• Proposal II: The so-called “Stop-the-clock” proposal

Omnibus I – Thresholds & content adjustments

The EU Commission is proposing to raise the thresholds for the CSRD and EU Taxonomy. Building on this proposal, the EU Council has put forward a further adjustment, which involves raising the thresholds again – including extending them to the CSDDD. This would mean that around 80% of companies currently subject to mandatory reporting would no longer be required to do so in the future. 

CSRD originally: 

• Threshold:
  o    two out of three criteria: > 250 employees, > €50m turnover,> €25m balance-sheet total

CSRD new: 

• Threshold:
  o    > 1,000 employees and turnover > €450m or balance-sheet total > €25m

EU Taxonomie originally: 

• Threshold:
  o    same as for CSRD
• Materiality:
  o    no materiality threshold

EU-Taxonomie neu: 

• Threshold:
  o    > 1,000 employees and turnover > €450m
• Materiality:
  o    from 10% sustainable turnover, CapEx and OpExx

CSDDD originally: 

• Threshold:
  o    >1,000 employees and > €450m turnover

CSDDD new: 

• Threshold:
  o    > 5,000 employees and turnover > €1.5bn

Carbon Border Adjustment Mechanism (CBAM) originally: 

• Threshold:
  o    value limit of €150

Carbon Border Adjustment Mechanism (CBAM) new: 

• Threshold:
  o    > 50 tonnes of imports/year (de minimis)

EFRAG was tasked with revising the ESRS with the aim of reducing the data points, clarifying unclear requirements and bringing them more closely into line with other legislation. The consultation begins in July 2025, with the final recommendations due in October 2025. 

Changes are also planned for the CSDDD: 

• Restriction to Tier 1 suppliers (as with the SCA)
• Checking due diligence processes only every five years
• Member states will be able to define their own penalty and civil liability regulations in future

CBAM-compliant reporting is to be simplified as follows:

• Companies have until 31 August to submit their CBAM declaration (instead of 31 May)
• The declaration can be delegated to third parties
• Emissions trading will be postponed until 2027

The transition phase until the end of 2025 remains unchanged. Sanctions for incorrect reporting are still possible.

Omnibus II – Deadline extension

In a summary process on 16 April 2025, the deferment of the CSRD- and CSDDD-compliant reporting obligations took effect through publication in the Official Journal.

Consequently, the CSRD will not be applied for two years: 

Wave 2: 

• First use originally due: 2026 
• First use now due: 2028

Wave 3:

• First use originally due: 2027 
• First use now due: 2029

This also affects the CSDDD:

Wave 1: 

• First use originally due: 2027
• First use now due: 2028

Wave 2:

• First use originally due: 2028 
• First use now due: 2029

Wave 3: 

• First use originally due: 2029 
• First use now due: 2030

The first CSRD user group, which has to report on the 2024 business year in 2025, is not affected by the “Stop-the-clock” proposal. On 13 May 2025, however, the EU Commission announced a delegated act that allows for temporary relief for these companies – especially to avoid unnecessary overhead for data gathering. An exact publication date has not yet been given.

Trilogue process & outlook

The content changes to the CSRD, ESRS and CSDDD are currently being prepared for the so-called trilogue process. This means that, as well as the original proposal of the EU Commission, both the Parliament and the Council are developing their positions. Only when both institutions have officially decided their viewpoints will the trilogue negotiations begin, with the aim of reaching an agreement that can be accepted by both fellow legislators. This provisional agreement must then be ratified in a formal procedure.

It is hoped that an agreement will be reached by the end of 2025:

• Position of Parliament: July 2025
• Position of Council: 24 June 2025
• Start of trilogue: expected November 2025

In the case of the CBAM changes, Parliament and the Council have already agreed on their respective positions (on 22 and 27 May 2025, respectively), so the scheduled trilogue negotiations can begin.

This is unlike the situation with the EU Taxonomy, where no trilogue negotiations will take place. The European Parliament and the Council can only formally object to legal acts proposed by the Commission. The changes are scheduled to come into effect on 1 January 2026.

The following links offer further support.