The Omnibus package suggests the following core amendments to EU sustainability legislation, though these will need to be approved by the European Parliament: 

CSRD

• New thresholds:
  • EU companies with over 1,000 employees, and either more than €50 million turnover, or more than €25m assets need to report. This exempts 80% of EU companies from mandatory reporting.
  • Non-EU companies with over €450m turnover generated in the EU and at least one EU branch with a turnover of more than €50m need to report from 2028.
• Companies with over 1,000 employees can report voluntarily.
• Two-year postponement of reporting deadlines. Applies to companies due to report in 2026 and 2027.
• No sector-specific reporting guidelines.
• Simplified data collection and reporting.
• Limited assurance only with no requirement to transition to reasonable assurance.

CSDDD

• Due diligence requirement reduced to direct suppliers (Tier 1).
• Postpone reporting deadlines by one year to mid-2028.
• No information requests to suppliers with less than 500 employees apart from voluntary SME standards.
• Monitoring of due diligence measures required every five years, not annually.
• No obligation to terminate contracts for non-compliant suppliers.
• No obligation to put transition plan into effect. 

CBAM

• New threshold: businesses with over 50 tonnes in imports. This exempts approximately 90% of EU importers.
• Full implementation date remains 1 January 2026. Certificates to be bought from 1 January 2027, covering emissions from imports in 2026.
• Simplified emissions tracking, data collection and reporting.

EU Taxonomy

• New threshold: only companies with over 1,000 employees and more than €450m turnover need to report.
• Companies below this threshold can report voluntarily.
• Financially immaterial activities (representing less than 10% of the business) can be excluded.
• Banks can exclude exposures linked to companies outside the future CSRD scope from their Green Asset Ratio calculations.
• Simplified reporting templates, reducing data points by nearly 70%.

For further details and updates, please visit the European Commission’s website. 

No.

The Omnibus has entered the EU legal process, where it needs to be reviewed and accepted by the European Parliament and the European Council before it is transposed into law by EU member states. As it stands nothing has been passed into law, meaning the proposed changes do not yet apply. Reporting should remain part of business-as-usual in line with the original timelines and requirements. In the meantime, businesses should closely monitor the implementation of any changes across the EU member states where they operate, as each country has up to a year to incorporate EU regulations into national law after the proposal has been accepted.

The proposed Omnibus package has officially entered the EU’s legislative process, during which the European Parliament and the European Council need to approve the changes. The EU has requested to fast-track this process and hopes to come to an agreement by the end of 2025. This would mean that by June 2026 these changes would be published into the ‘Official Journal of the European Union’. In the meantime, changes can be lobbied, and concessions can be made to the proposed package, which could lead to further delays.

The recent announcement, and subsequent uncertainty, risks companies postponing important progress in this space. Until there is a consensus in the European Parliament, businesses must continue to meet existing reporting deadlines. For instance, if your company’s CSRD deadline is set for 2026 under current legislation, this timeline remains unchanged unless stated otherwise. Find out more in our briefings on CBAM, CSRD and the EU Taxonomy. 

Many companies have already invested in important infrastructure to comply with existing legislation. We encourage the continuation of these efforts, reaching beyond regulatory compliance and reporting. Adjusting current processes and ways of working while the proposed simplification measures are undergoing review could lead to greater uncertainty, reduced buy-in from stakeholders and require additional time and human resources in the future. We recommend businesses:

• Proactively monitor regulatory developments through internal and external working groups.
• Continue to work towards Net Zero, viewing reporting as a strategic rather than a compliance exercise.
• Prepare for potential upcoming changes.

As reporting requirements and the regulatory landscape will continue to be in flux, it’s important for businesses to ensure their sustainability resources are agile and can seamlessly pivot from reporting functions (as and when needed) to other key areas that help their journey to Net Zero.

This state of uncertainty emphasises the need for clear communication, both internally and externally. 

Internal teams

Cross-departmental communication will be key to managing change. Sales, procurement, legal and compliance staff need to be kept informed of any potential changes that will affect the way they work. Monitor amendments to the Omnibus package and assess what the impact of any decisions by the EU will have on the business. Align current reporting and decarbonisation plans with resources and, where possible, focus on further emissions reductions work.

Suppliers and the wider value chain

Set clear expectations with your suppliers on measuring and reducing Scope 3 emissions, which remain one of the biggest obstacles to achieving Net Zero. While the proposed changes may exert less pressure, ongoing supplier collaboration presents opportunities not only to reduce these emissions but cut costs, drive consumer demand, and futureproof the value chain.

If proposed changes mean businesses need to adjust how they collect emissions data, they should communicate this to suppliers well in advance to allow for a timely adoption.

This is particularly relevant to companies with science-based targets, those that participate in CDP reporting, or those involved in other non-governmental frameworks who will continue to engage their value chains and collect emission data, irrespective of evolving regulatory requirements. 

Investors and consumers

Interest in sustainable investing remains high. According to a recent study, ‘over 70% of individual investors‘ believe strong ESG practices can lead to higher returns.’ With the changes proposed in the Omnibus package, certain information previously disclosed in companies' annual statements and sustainability reports may no longer be part of a mandatory disclosure exercise but may still be required by investors. For example, in the context of sustainability-linked performance indicators tied to loans.

Consumers also show a positive sentiment towards sustainability as they wish to better understand the environmental impact businesses and products have, and the steps they are taking to mitigate it. The Carbon Trust’s survey on carbon footprint labelling, for example, found that two-thirds of consumers surveyed think that it is a good idea to feature carbon labels on products.

The Omnibus package aims to reduce the administrative burden on businesses. As part of this, some data points related to CSRD or the EU Taxonomy may be consolidated, meaning not all existing data requests to suppliers may be necessary for compliance.

As we await further details on these simplifications, data is still paramount in planning and advancing your Net Zero transition. It provides insights into where decarbonisation efforts should be prioritised, allowing you to track progress and make the business case for further climate action.

Even if the Omnibus package is approved in its current form and your company no longer needs to adhere to EU sustainability reporting requirements, the importance of understanding the impact of climate change in your business will persist. You will still require data from your suppliers and value chain partners to fully understand your company's climate impact. Try to identify where your organisation can make real carbon emissions reductions across the value chain and understand what type of data is needed to make these decisions. Doing so, you can continue to invest in optimising data quality and collection processes where these would have the biggest impact.

In light of the proposed changes, making the internal business case for continued climate action becomes even more critical. While your company may no longer need to comply with EU reporting legislation, the benefits of aligning sustainability with long-term business strategy and priorities remain. Taking sustainability beyond compliance can lead to:

• Operational costs savings from using energy and resources more efficiently.
• Resilience against market turbulence (including energy price shocks) and regulatory changes.
• Futureproofing supply chains and business models, protecting business value.
• Potential access to capital and new opportunities in the low carbon economy, as the EU seeks to drive sustainable investment through the European Green Deal.
• Enhanced reputation and brand loyalty through market-leading sustainability commitments.
• Competitive advantage via market differentiation and innovation.