#Knowledge
Sustainability reporting
EU Omnibus Proposal – New momentum in the discussion of CSRD and CSDDD (as of October 2025)
What you need to know now about the planned EU Omnibus Regulation
What you need to know now about the planned EU Omnibus Regulation
On October 22, 2025, the EU Parliament rejected the negotiating mandate proposed by the Legal Affairs Committee (JURI) on the so-called “Omnibus” package. This means that there is currently no official parliamentary position vis-à-vis the Council and the Commission – the planned trilogue negotiations have been halted for the time being. The omnibus proposal originally aimed to simplify the obligations under the CSRD (Corporate Sustainability Reporting Directive) and the CSDDD (Corporate Sustainability Due Diligence Directive) and to reduce their scope – among other things, by setting significantly higher thresholds (1,000 employees and €450 million in revenue for CSRD; 5,000 employees and €1.5 billion in turnover for CSDDD) and relief for SMEs.
The next step is now a new vote in plenary on November 13, 2025. Only then can a revised parliamentary position be adopted and clear the way for new trilogue negotiations. But for now, legal uncertainty for companies remain. The current requirements under CSRD and CSDDD remain fully valid. In practice, this means that companies should continue to plan and report in accordance with existing sustainability guidelines, while closely monitoring developments in November.
The discussion on ammending sustainability reporting requirements began in early 2025. On February 26, 2025, the EU Commission presented a draft of the so-called Omnibus Regulation. The aim was to reduce the administrative burden on companies, facilitate an altered implementation of the CSRD and CSDDD requirements, and give enterprises more time to comply with the regulations.
On April 3, 2025, the European Parliament voted on sections of the draft, leading to further delays in reporting requirements. The planned changes concerned, among other things, sustainability reporting requirements like the Supply Chain Directive (CSDDD), the Carbon Border Adjustment Mechanism (CBAM), and the EU taxonomy. The aim was to simplify reporting, particularly for companies in the first and second reporting phases, without changing the core requirements of the EU sustainability rules.
This proposal launched the omnibus process, which was further developed and discussed in the following months and forms the basis for the current adjustments.
In recent months, several measures have already been adopted or prepared as part of the EU Omnibus Proposal with the intention of bringing tangible relief to businesses:
CBAM (Carbon Border Adjustment Mechanism): The omnibus amendments to the CBAM came into force on October 20, 2025.
The main changes are:
CSDDD (Corporate Sustainability Due Diligence Directive): The omnibus proposal also provides for timing adjustments and content restrictions for the CSDDD:
Double materiality analysis: Double materiality remains part of the CSRD and ESRS regimes, meaning that companies must continue to consider both the impact of sustainability issues on their business (inside-out) and the impact of their business on the environment and society (outside-in).
Simplified reporting: The European Sustainability Reporting Standards (ESRS) were revised by EFRAG in the summer of 2025 and published in the form of new drafts. The aim was to simplify the requirements and significantly reduce the scope of disclosure obligations. Public consultations have now been completed and the final adjustments are currently being reviewed by the European Commission before they are expected to come into force in early 2026.
ESEF reporting obligation: The obligation to report in ESEF (European Single Electronic Format) has been temporarily suspended or postponed as part of the Omnibus Package. The final decision depends on the Parliament’s plenary vote on November 13, 2025.
EU taxonomy: The current adjustments concern:
The review by Parliament and the Council is still ongoing. The scrutiny phase has been extended until January 2026. The final rules will not be published until then.
Quick fix for Wave 1 companies: For companies that are already required to report (Wave 1), the obligations for 2025 and 2026 are to be significantly reduced. The quick fix provides for certain reporting obligations to be suspended or mitigated, so that the effort required in these years can be significantly reduced.
Stop-the-clock for Wave 2 companies: The omnibus measure provides for companies in the second wave to postpone their entry into CSRD reporting requirements by two years: Instead of having to report as early as 2026, they would report for the first time for the 2027 financial year — i.e., in 2028. This gives affected companies additional time for data collection, processing, and system integration.
What remains to be decided:
The thresholds for CSRD reporting requirements (number of employees and turnover) have still not been finalized.
The same applies to the CSDDD thresholds and the final design of the EU taxonomy, including reporting templates and materiality thresholds.
A new vote in the EU Parliament is scheduled for November 13, 2025. Only then can the trilogue negotiations between the Commission, the Council, and the Parliament begin.
The coming months will determine how quickly and to what extent the new EU regulations will be implemented. Companies should actively use this phase to prepare themselves. An important first step is to keep a close eye on regulatory developments—in particular, the plenary vote of the EU Parliament on November 13, 2025, and the subsequent trilogue negotiations. These dates will be decisive in determining when and how the new requirements actually come into place.
Based on this, it is worth developing different scenarios: a minimum plan in case the introduction is delayed again, and a comprehensive implementation plan in case the regulation is adopted quickly. This will allow the company to react flexibly in both cases.
A careful gap analysis is equally important. This involves critically reviewing existing data, processes, and systems and specifically closing gaps that are relevant for future sustainability reporting. Those who recognize room for improvement early on can implement adjustments efficiently and will be well prepared when the new obligations become binding.
“Even though the omnibus proposals are still up in the air, it is worth establishing and refining structures for sustainable reporting. It is about much more than just a report: those who collect data on climate, social, and governance aspects at an early stage can make informed decisions in the current turbulent economic situation, optimize processes, and at the same time prepare for the final CSRD requirements.”
– Sibylle Zavala, Cluster Lead Sustainability
The EU omnibus proposal marks a decisive turning point in the development of European sustainability regulation. Even if the rejection of the current mandate by the EU Parliament is causing uncertainty, one thing is clear: the discussion about a more practical, yet still ambitious, design of CSRD and CSDDD is in full swing. Companies should actively use this interim phase to strategically prepare for various scenarios and further strengthen their internal structures.
The coming weeks, especially the vote on November 13, 2025, will be decisive. Until then, it is important to observe closely, plan flexibly, and close existing data and process gaps in a targeted manner. Those who act now will lay the foundation for efficiently implementing future requirements and positioning themselves in the long term as reliable and transparent players in an increasingly sustainability-oriented market environment.
