Omnibus I package (as at February 2026)

The Council of the European Union formally adopted the so-called Omnibus I package on February 24, 2026. This concludes the legislative process at EU level. The legislative text will be published in the Official Journal of the European Union in the coming days. It will enter into force 20 days after publication. From this point in time, the transposition into national law will begin, for which the member states will have the implementation deadlines provided for in each case.

In this article, we give you an overview of the key points of the omnibus package and the entire debate.

Key points of the omnibus package: as of February 2026

Areas of application:

• CSRD: Thresholds raised to 1,000 employees (FTE) and € 450 million net turnover
• CSDDD: Thresholds raised to 5,000 employees (FTE) and €1.5 billion turnover

Transition plans:

• CSRD / ESRS: Climate transition plans are no longer mandatory across the board, but are only relevant in the case of materiality and as part of the risk-based reporting approach.
• CSDDD: The obligation to draw up a transition or climate adaptation plan no longer applies.

Due diligence for CSDDD:

• Introduction of a purely risk-based approach
• Focus on direct business partners
• Expansion along the value chain only in the case of concrete and plausible risks

Civil liability:

• No EU-wide uniform liability framework, application of national liability regulations
• CSRD: No introduction of new civil liability; the existing national regulations remain in place.
• CSDDD: Limitation of liability to up to 3% of the company’s global turnover.

Further changes:

• Reporting should be more quantitative overall
• No sector-specific reporting obligations
• Introduction of a digital portal for companies (templates & guidelines)

Changes to the ESRS

The revised ESRS bring significant simplifications and relief for companies. The focus is more on the usefulness of decisions and materiality as a general filter. Proportionality mechanisms and simplifications as well as a phased entry into force reduce the effort considerably. Narrative disclosures will in future follow principles-based standards, and there is more flexibility in reporting in line with the management of material risks and opportunities. Overall, 61% of the data points have been deleted and the number of pages in the standards is less than 45% of the original scope. According to the cost-benefit analysis, there are annual cost savings of over 30%, particularly as a result of the phase-in regulations.

1. Simplified materiality analysis: The assessment of materiality is becoming more flexible: companies can choose between a top-down or bottom-up approach. Qualitative considerations are often sufficient, the number of topics has been reduced and the documentation requirement is lower.
2. Better readability of reports: More flexibility in presentation ensures clearer communication. Content can be moved to attachments, the report focuses on essential information and avoids unnecessary complexity.
3. Reduced disclosure requirements in topic standards: companies decide for themselves where information such as policies or objectives appear. The requirements have been simplified and many mandatory details have been removed or moved to optional guidelines.
4. Shorter and more comprehensible standards: The standards are streamlined and easier to implement. 61% of data points have been removed, voluntary disclosures have been completely eliminated and application notes have been integrated to facilitate implementation.
5. Improved compatibility with international standards: Standardized terms and the fair presentation principle ensure that reports reflect the actual situation. Transition periods and simplifications for complex disclosures facilitate adaptation.
6. Comprehensive relief for difficult disclosures: Exemptions for disproportionate effort, the possibility of estimates and the protection of confidential information reduce the burden. Phase-in rules and proportionality mechanisms round off the simplifications.

What has already been implemented?

In recent months, several measures have already been adopted or prepared as part of the EU omnibus proposal and the new sustainability regulations, which are intended to bring tangible relief to companies:

Quick fix for Wave 1 companies: For companies that are already obliged to report today (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 burden can be significantly lower in these years.

Stop-the-clock for Wave 2 companies: The omnibus measure provides for companies in the second wave to postpone their entry into the CSRD reporting obligation 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. from 2028. This will give affected companies additional time for data set-up, processes and system integration.

CBAM (Carbon Border Adjustment Mechanism): The omnibus amendments to the CBAM came into force on October 20, 2025. The main changes are:

• • Introduction of a minimum threshold of 50 tons per year and material group, which will significantly reduce the burden on smaller importers.
  • Postponement of the first mandatory CBAM report to September 2027 (for the 2026 reporting year)

These changes significantly reduce the administrative burden and extend the transition phase.

ESEF reporting obligation: The ESEF obligation for sustainability information will not be introduced on the original timetable, but will be postponed until the regulatory framework (in particular simplified ESRS) is in place. The exact new dates for mandatory application will be determined after publication in the EU Official Journal (early 2026) and with the delegated acts.

EU taxonomy: The current adjustments relate in particular to the introduction of materiality thresholds, an optional opt-in procedure and a reduction in reporting obligations and templates.
The review by Parliament and Council was continued as part of the omnibus package; the scrutiny phase was extended until January 2026. The final regulations will enter into force once this phase has been completed and published in the Official Journal of the EU.

Next steps

Following the Council decision of February 24, 2025, the focus is now shifting to the practical design and national implementation of the Omnibus I package. In the coming months, the delegated acts in particular, especially the simplified ESRS, will be further fleshed out, thus creating the de facto basis for future sustainability reporting.

What does this mean for companies?

For companies, this marks the beginning of a phase of strategic classification: less formal obligations open up scope, but at the same time require conscious decisions as to whether, how and to what extent sustainability information should be collected, managed and reported in future. Against this backdrop, existing CSRD activities should be reviewed, streamlined and focused more strongly on essential, management-relevant content.

How it all began: a look back at CSRD and the omnibus proposal

The discussion on simplifying 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 the implementation of the CSRD and CSDDD requirements, and allow additional time for compliance with the new reporting requirements.

The European Parliament voted on parts of this draft as early as April 3, 2025. This vote led to a further delay in the reporting requirements. The planned changes concerned, among other things, the sustainability reporting requirements under the CSRD, the Supply Chain Directive (CSDDD), the Carbon Border Adjustment Mechanism (CBAM), and the EU Taxonomy. The aim was, in particular, to provide companies in the first and second reporting phases with noticeable relief in their reporting without fundamentally changing the core requirements of European sustainability regulation.

The Commission’s proposal marked the start of the omnibus process, which was intensively developed and politically discussed in the following months and formed the basis for the expected adjustments for a long time.

On October 22, 2025, however, the European Parliament rejected the negotiating mandate proposed by the Legal Affairs Committee (JURI) on the so-called “Omnibus” package. This meant that at that point in time, there was no official parliamentary position vis-à-vis the Council and the Commission, and the planned trilogue negotiations were halted for the time being.

In the meantime, the political situation has evolved: The omnibus proposal has been adopted, thus completing the previously interrupted legislative process. The EU Parliament approved the omnibus package in plenary on December 16, 2025, after the Council (December 10) and the Legal Affairs Committee (December 11) had given the green light. This concluded the trilogue procedure.

Our expert assessment

“Now that the Omnibus Package has been adopted, it is advisable for companies to continue to develop and refine their structures for sustainable reporting in a targeted manner. Even though individual detailed regulations will only be finalized once they are implemented at the national level, this has long been about more than just fulfilling reporting obligations. Companies that collect reliable data on climate, social, and governance aspects at an early stage create a sound basis for decision-making in a continuing volatile economic environment, can make internal processes more efficient, and are well prepared for the final CSRD requirements.”

– Sibylle Zavala, Cluster Lead Sustainability