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.
Omnibus: On October 22, an initiative to accelerate starting negotiations between the co-legislators (known as the trilogue) failed to obtain a majority in the European Parliament (EP). This means that the Content Directive revisions previously endorsed by the EP Legal Affairs Committee on October 13 could see further amendments made. The EP is expected to vote in mid-November to adopt the position it will carry intro trilogue negotiations with the European Commission (EC) and Council of the EU (Council), which will begin shortly thereafter.
NESRS: In early October, the EC announced a de-prioritization process that would delay certain acts, including the adoption of reporting standards for non-EU groups (NESRS), until at least October 2027. Scroll down to the ‘Other developments’ section to read more.
ESRS: On September 29, the public consultation period ended for the European Financial Reporting Advisory Group’s (EFRAG’s) proposed revisions to the European Sustainability Reporting Standards (ESRS). Read our web article, Proposed amendments to simplify ESRS.
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.
Click on the links to understand more about EU sustainability reporting.
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
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
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 ECOur Hot Topics, tailored to US companies, provide information on the relevant scoping and reporting requirements, as adopted by the EU.
Global implications of EU sustainability reporting
Omnibus proposals could significantly reduce the scope of the CSRD and its applicability beyond the EU
Global implications of due diligence acts
Omnibus proposals aim to significantly streamline due diligence obligations and ease burden on companies
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.
Outside the Omnibus, a lot is still happening with the CSRD and CSDDD. Hover over each of the following boxes to read the latest.
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).
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).
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).
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).
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).
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).
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
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
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.
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.
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.
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.
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; the proposed Content Directive would bring forward this date by 6 months to July 26, 2026.
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; the proposed Content Directive would bring forward this date by 6 months to July 26, 2026.
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. The EC and Council have proposed 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. The Council has proposed postponing this assessment by one year. It is not yet clear what all three legislative bodies will agree upon.
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. The EC and Council have proposed 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. The Council has proposed postponing this assessment by one year. It is not yet clear what all three legislative bodies will agree upon.
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