November 13, 2025

Sustainability reporting in the EU

US companies could be impacted by sustainability reporting and due diligence requirements in the EU – notably the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).

Get grounded, stay ahead

While the CSRD and CSDDD have been adopted into EU law, an Omnibus package introduced in February 2025 is making substantive changes to both directives.

For a foundational overview of the CSRD and CSDDD, including changes introduced by the Omnibus Stop-the-clock Directive  and the European Commission’s (EC’s) proposed Content Directive, read our Hot Topics linked below.

For an overview of the latest developments on all the moving parts of EU sustainability reporting, including Omnibus updates, continue scrolling – and regularly check the timelines below for key updates.

Latest: Proposed Content Directive moves forward as Parliament adopts its position

US companies – here’s what matters most
Although uncertainty still abounds, the EP's adoption of its negotiating position for the proposed Content Directive signals that significant changes to the CSRD and CSDDD scoping thresholds are highly likely. While the proposed scoping threshold revisions vary between co-legislators, US companies can begin assessing the impact each of the different sets of proposed scoping thresholds could have on their sustainability reporting strategy.

On November 13, the European Parliament (EP) voted to adopt its negotiating position on the proposed Content Directive. This marks a significant step as it becomes almost certain that there will be significant changes to the CSRD and CSDDD, as compared to the original text adopted by the EU, including significant changes to scoping thresholds.

The EP vote paves the way for negotiations (known as trilogues) with its' co-legislators, the Council of the EU (Council) and the European Commission (EC) to begin, with the aim of concluding negotiations by year-end. The table below compares the Content Directive proposals from each of the co-legislators.

Understand EU sustainability reporting

Here you’ll find key information to help you navigate the evolving EU sustainability reporting landscape. Use the jump links below to quickly access specific topics.

Overview of the CSRD, CSDDD and Omnibus

Click on the links to understand more about EU sustainability reporting.

CSRD

CSRD

The CSRD amends the Accounting Directive (2013/34/EU), which applies to non-EU companies that meet certain employee, turnover (revenue) and/or asset thresholds; and to non-EU groups with substantial activity and a presence in the EU. In-scope companies are required to prepare sustainability reporting in accordance with the ESRS.

Directive 2013/34/EU
CSDDD

CSDDD

The CSDDD (2024/1760) applies to non-EU companies that meet certain revenue and/or royalty thresholds. In-scope companies are required to comply with certain due diligence obligations (including reporting and transition plan adoption) related to actual and potential adverse human rights and environmental impacts.

Directive 2024/1760
Omnibus

Omnibus

A package of directives and proposals intended to simplify sustainability reporting and due diligence requirements – including the CSRD and CSDDD – while still achieving the overall ambition of the European Green Deal. With this package, the EC aims to significantly reduce administrative burdens, increase legal clarity, and support businesses in their transition toward sustainable and competitive operations within the EU market.

Omnibus package, proposed by the EC

Key Omnibus milestones

The EC’s efforts to simplify and streamline certain EU legislation (including the CSRD and CSDDD) are being executed via a series of Omnibus packages and other simplification measures. These measures are being introduced in waves, with different parts progressing at varying speeds.

To help you stay informed, we’ve created five separate timelines – each tracking a specific piece of the Omnibus package. This approach will give you a clearer view of the distinct regulatory pieces and their unique paths forward.

Click each of the boxes below to view a timeline of what’s happened so far and what’s expected next. As legislative discussions evolve, future dates may shift, so check back regularly for the latest updates.

 

Other developments

Outside the Omnibus, a lot is still happening with the CSRD and CSDDD. Hover over each of the following boxes to read the latest.

CSRD: Transposition

The CSRD entered into force in January 2023. Despite the deadline of July 6, 2024 to transpose it into national law, a handful of Member States have not yet transposed.

For Wave 1 companies, these delayed transpositions continue to cause legal uncertainties relating to, for example, continued application of the sustainability reporting regime under the Non-Financial Reporting Directive (NFRD).

CSRD: Non-EU standards

Non-EU groups in scope of the CSRD are required to report in accordance with the forthcoming non-EU group standards (NESRS). The EC’s adoption deadline for the NESRS is June 30, 2026. However, a de-prioritization process proposed by the EC would further delay this timeline until at least October 2027. Certain non-EU groups would still be required to comply with the CSRD, and this delay would leave little time for them to prepare for reporting in FY2029 (based on FY2028 data).

CSRD: Guidance

To support CSRD implementation, EFRAG has developed a Q&A process and issued nonauthoritative guidance on double materiality, value chain and ESRS datapoints. Additional nonauthoritative guidance on other topics will likely not be released before EFRAG provides its draft revisions to the EC on the first set of ESRS (see ‘Proposed ESRS simplifications’ timeline above).

CSRD: VSME

The EC has adopted a recommendation on voluntary sustainability reporting for SMEs that includes a voluntary standard for SMEs (VSME). The EC is encouraging companies in scope of the CSRD to leverage this standard when making requests to SMEs, to the extent possible.

The EC still plans to adopt a delegated act on a voluntary standard. The timing of this adoption will depend on the progress and outcomes of the ongoing Omnibus proposal negotiations. Read our web article, VSME: A voluntary sustainability reporting option

CSRD: Assurance

The CSRD requires the EC to adopt limited assurance standards by October 2026. While the EC is proposing to remove this requirement (instead, requiring the EC to issue targeted assurance guidelines), it is not yet clear what all three legislative bodies will agree upon as the EP has included this requirement, as adopted, within its negotiating position.

CSDDD: Transposition

The CSDDD entered into force in July 2024. The Stop-the-clock Directive officially extends the transposition deadline to July 26, 2027. To avoid a fragmented regulatory landscape, a harmonization principle allows Member States to introduce into their national law more stringent and/or specific provisions but prohibits divergence from certain due diligence obligations. The proposed Content Directive would expand the harmonization principle to further aspects of the due diligence process.

CSDDD: Guidance

By March 31, 2027, the EC will establish the CSDDD report content and criteria, which are expected to align with similar reporting criteria in the CSRD.

The EC will issue guidelines to support companies in fulfilling due diligence obligations in a practical manner. This includes practical guidance on the transition plan by July 26, 2027, and general guidelines by January 26, 2027. While the EC is proposing to bring forward this date by 6 months to July 26, 2026, it is not yet clear what all three legislative bodies will agree upon.

CSDDD: Assessments

By July 26, 2026, the EC will assess the need for additional due diligence requirements for regulated financial undertakings related to the provision of financial services and investment activities. While the EC is proposing to eliminate this assessment, it is not yet clear what all three legislative bodies will agree upon.

By July 26, 2030, the EC will assess the effectiveness of certain implementation matters, including whether a scoping approach specific to high-risk sectors should be introduced and whether the value chain definition should be revised. While the Council is proposing to postpone this assessment by one year, it is not yet clear what all three legislative bodies will agree upon.

Explore more

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