What is the EU omnibus?

As a response to concerns raised by several stakeholders regarding the complexity of European sustainability legislations, EU Commission was considering consolidating the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Taxonomy into one omnibus regulation. 

As a result of this package, the number of companies required to report under the European Sustainability Reporting Standards (ESRS) has been reduced, with a smaller group continuing to report under the EU Taxonomy, as detailed below. These changes must be approved by both the European Parliament and the Council of the EU and incorporated into national law to take effect. Additionally, the Commission has stated its intention to simplify ESRS disclosure requirements and is consulting on potential amendments to the EU Taxonomy.

The initial omnibus proposal, released on 26th of February 2025, brings several changes to existing sustainability directives. Here is a list of main proposed changes and how it can impact your business.

For CSRD, the main changes include: 

• The CSRD and EU Taxonomy reporting requirements are proposed to be postponed for two years (until 2028) for companies currently in the scope of CSRD as part of Wave 2.
• Definition of new thresholds for CSRD reporting for Wave 1 companies, Large public-interest entitiesand Wave 2 – Large EU-Company, proposed thresholds are:
  • more than 1000 employees and
  • net turnover above EUR 50 million OR total assets above EUR 25 million;
• Value chain cap (limiting the information that companies or banks falling into the scope of the CSRD can request from companies in their value chains with fewer than 1,000 employees);
• Planned revision of ESRS: fewer compulsory data points to disclose, focus on quantitative data, certain data points will become voluntary;
• Removal of requirement to apply sector-specific standards.

Below is a summarization of the most important proposed changes under existing CSRD:

* Local current thresholds as adopted in Romanian legislation are significantly lower than those established in EU regulation, as such there is a possibility that if and when adopted locally, the modified thresholds are different that those under Omnibus EU initiative.

** for current Wave 1 entities that do not meet the proposed threshold, there will be no reporting requirements. However, the timing remains uncertain due to the adoption and transposition process.

*** not meeting proposed threshold means no reporting requirement

**** not meeting proposed threshold means no reporting requirement

For EU Taxonomy, the main changes include:

• Limiting the EU Taxonomy reporting obligations to the largest companies (companies with more than 1000 employees and €450m net turnover), while keeping the possibility to report voluntarily for the other large companies within the future scope of the CSRD.  
• In the EU Taxonomy, simplifications to the most complex “Do no Significant harm” (DNSH) criteria for pollution prevention and control related to the use and presence of chemicals to all economic sectors. 
• Option to omit reporting on activities that make up less than 10% of total turnover, CapEx or OpEx;
• Simplifications of Taxonomy-based KPIs for banks. Banks will be able to exclude from the denominator of the Green Asset Ratio (GAR) exposures that relate to undertakings which are outside the future scope of the CSRD (i.e., companies with less than 1000 employees and €50m net turnover or €25m balance sheet). 
• Ensure that sustainability reporting requirements on large companies do not burden smaller companies in their value chains by adoption of a voluntary reporting standard (VSME).

The complete list of the Omnibus proposed measured, can be consulted on EU Omnibus press release. 

Next steps depend on EU adoption and national transposition.

These changes must be approved by both the European Parliament and the Council of the EU, Official Journal publication and incorporated into national law to take effect, with the Omnibus’ recommendation being that the proposed measure to postpone the CSRD for Wave 2 and Wave 3 entities to be transposed by EU State Members by 31 December 2025 through an urgent procedure.

• If you are a large EU PIE to continue the process and consider the following:
  • Revisit scoping exercise according to newly proposed thresholds
  • Continue implementation effort and closely monitor regulatory developments
  • If below thresholds also consider what voluntary ESG or EU Taxonomy reporting is necessary based on stakeholders/ capital market expectations
• If you are a large EU-Company we suggest to keep moving and consider the following:
  • Maintain your implementation efforts while closely tracking CSRD 1.1 proposed measures (which proposes a postponement for wave 2 until the end of 2025 through an urgent procedure),
  • Reevaluate your current implementation plan and make adjustments as needed,
  • If you fall below the threshold, assess whether any voluntary ESG reporting is required based on stakeholder expectations,
  • Identify "no regret" actions, such as conducting a double materiality assessment.