These days, some CFOs are eagerly and sustainability managers awaiting the publication of the omnibus procedure by the EU Commission. The draft is now available to view and we analyse the changes that will affect CSRD, CSDDD, taxonomy and CBAM
The omnibus directive: Increasing efficiency and promoting investment
On 26 February 2025, the European Commission published the drafts for the omnibus procedure with the aim of reducing regulatory complexity, facilitating investments and existing regulations applying in a more targeted manner. from the Green Deal The key objectives are a 25% reduction in administrative burdens for companies – and as much as 35% for SMEs – as well as optimised implementation of the Green Deal.
Omnibus I and Omnibus II introduce changes to several key areas, including the InvestEU programme, the Carbon Border Adjustment Mechanism (CBAM) and Corporate Sustainability Reporting Directive (CSRD), EU taxonomy ( TaxEU) and Corporate Sustainability Due Diligence Directive (CSDDD). We summarise the most important changes below.
Sustainability reporting becomes more accessible and efficient
In Germany many companies have been looking in the crystal ball due to the lack of national implementation of the Corporate Sustainability Reporting Directive (CSRD). Having been waiting could now be an advantage, as the omnibus package will bring significant changes to the reporting obligation.
- Reduced scope of application: In future, only companies with more than 1,000 employees (previously 250) and a turnover of more than EUR 50 million or a balance sheet total of more than EUR 25 million will be required to report. This reduces the number of companies affected by 80 %. The sustainability reporting obligation for companies from third countries will be lifted to a threshold value of EU.€ 450 million turnover
- Value chain ruling: Companies outside the reporting obligation (up to 1,000 employees) can no longer be obliged to make excessive sustainability data available to larger companies. The Commission will introduce a voluntary reporting standard for SMEs, on the basis of which reporting companies can request data.
- Revision of the sustainability standards (ESRS): The number of required data points will be reduced, sector-specific data points will be excluded and unclear regulations will be revised.
- Limitation of the audit obligation: The obligation to change from a “Limited Assurance” to a “Reasonable Assurance” no longer applies.
- Deadline extension: The introduction of reporting obligations for companies that were previously due to report from 2026 or 2027 has been postponed by two years.
Reduced due diligence obligations in the supply chain
The CSDDD also reduces effects and creates harmonisation with CSRD standards, thereby protecting SMEs and expanding the scope of action of obligated companies.trickle-down
- Deadline extension: The implementation deadline will be extended by one year. The first phase of application will now begin on 26 July 2028, while the Commission’s guidelines will be published in 2026 in order to provide companies with early guidance.
- Reduced due diligence obligations in complex supply chains: Companies only have to fulfil comprehensive due diligence obligations via direct business partners. An audit along the entire value chain is only required if there are specific indications of risks.
- Simplification of review intervals: The regular assessment of due diligence obligations now takes place every five years instead of annually. Adjustments are only necessary if there are reasonable doubts about the effectiveness of the existing measures.
- Limiting the “trickle-down” effect: large companies may only request the information defined in the voluntary CSRD standard (VSME) from SMEs and small mid-sized companies. Additional data may only be requested if it is absolutely necessary for a risk assessment.
- Flexibilisation of business relationships: The obligation to terminate business relationships as a last resort will no longer apply. Instead, companies should focus more on remedial measures.
- Changes in civil liability: The EU-wide liability regulations will no longer apply. Instead, responsibility is delegated to national civil law provisions.
- Harmonisation and clarifications: The requirements for climate transition plans will be adapted to the CSRD, while the harmonisation of the core obligations of the CSDDD will be strengthened.
Changes to the EU taxonomy and CBAM
The EU taxonomy will be simplified by allowing medium-sized companies with a turnover of up to € 450 million to voluntarily report on their sustainability orientation. In addition, the amount of reporting data required will be reduced by 70% and only economically crucial activities will have to be audited. Furthermore, the ” Do no Significant Harm ” (DNSH) criteria revised to make the environmental impact requirements more practicable.
With CBAM, small importers are relieved as companies with less than 50 tonnes of affected goods per year are exempt from the reporting obligations. In addition, the calculation of emissions is simplified as standardised values can be used.
No longer in scope: All work for nothing?
Have you already started preparing your report, but are now outside the direct scope of the CSRD? The work was still not in vain. SMEs that are no longer obliged to report are often indirectly affected, as larger companies or banks demand sustainability data from them.
The new regulations limit this “trickle-down” effect by introducing clear guidelines for data provision with the voluntary reporting standard (VSME). The provision of information according to the VSME will thus be standardised – but more attention will be paid to it with the harmonisation between CSRD and CSDDD
Especially if you are a direct supplier to large companies, you can make use of your preparatory work to provide data in accordance with the VSME standard. The double materiality assessment also retains its important function: it is still necessary for the report in accordance with VSME – but also for managing your sustainability strategy.
Are you run over by the omnibus? No problem: We support you in providing data in accordance with the VSME standard, prepare you for your due diligence obligations and support you in supplier evaluation in accordance with CSDDD.
Please note that all details and listings are not intended to be exhaustive, are without guarantee and are for information purposes only.
