What does the EU’s sustainability Omnibus mean for the CSRD and your ESG reporting?
First things first: what is the EU Omnibus?
“Omnibus” refers to a specific variation of the EU legislative process, where several pieces of related legislation are changed at the same time. This can include amending and/or repealing one or several EU laws, or parts of these laws. In practice, it is a patchwork legal text that refers to edits to be made in several other EU legal texts. Confusing? Yes. And there will be more to come, with the European Commission planning to issue further Omnibus proposals on subjects other than sustainability, with the overall ambition to cut red tape for businesses by 25% (and 35% for small-to-medium enterprises).
What will the sustainability Omnibus cover?
The sustainability omnibus package is expected to cover changes to the:
- Corporate Sustainability Reporting Directive (CSRD),
- Corporate Sustainability Due Diligence Directive (CSDDD),
- EU Taxonomy on Sustainable Economic Activities,
- and possibly other related laws.
What does this mean for non-EU companies?
The proposed EU Sustainability Omnibus Package revises the Corporate Sustainability Reporting Directive (CSRD), introducing higher thresholds that will impact non-EU companies with significant presence in the EU.
Key changes include:
| For financial years starting from 1 January 2027 (with first reports due in 2028): | For financial years starting from 1 January 2028 (with first reports due in 2029): |
|---|---|
| Non-EU companies trading on an EU regulated market must report if they have at least 1,000 employees and meet one of the following criteria: €50+ million net turnover €25+ million balance sheet total | Non-EU parent companies will be required to report if, at the group level, the net turnover generated in the EU is at least €450 million and has: At least one EU subsidiary (defined as a “large undertaking”), meeting two of three criteria: €50+ million net turnover €25+ million balance sheet total 250+ employees (average during the financial year) OR an EU branch that generates a net turnover of more than €50 million. |
While these changes may exempt some US and non-EU companies from the reporting requirements, the Omnibus Package is still under negotiation, and broader regulatory and market expectations around sustainability disclosure remain unchanged. In order to maintain EU market access and meet investor expectations, companies should capitalize on this time to:
- Assess reporting obligations early—companies near the new thresholds should monitor applicability.
- Strengthen sustainability reporting systems to align with ESRS standards and future compliance requirements.
- Enhance data collection and disclosure readiness, even if not immediately in scope, to maintain credibility with investors and stakeholders.
If you are looking to understand where your business stands relative these proposed changes, please reach out to our team.
Fact vs. speculation
Naturally, rumours about what this latest Omnibus will mean are circulating. But the only real facts (at the time of writing) are:
- The EU’s Corporate Sustainability Reporting Directive (CSRD) is adopted and is legally in force.
In countries where the CSRD has been transposed, companies must report according to the original CSRD deadlines until the EU and/or national laws are formally amended (if they end up being amended at all). Example countries include France, Italy, Ireland, Belgium, Denmark, Norway, Finland and Sweden.
- Most EU countries have transposed the CSRD into their national laws.
Only a few EU countries – for example Germany and Austria – have not yet transposed the CSRD into their national legislation, and are therefore in breach of EU legislation. Companies headquartered in these countries are currently under no obligation to report. However, legal experts generally agree that, as soon as the CSRD is transposed in these countries, companies must report the following year. For example, even if Austria only adopts its national legislation implementing the current CSRD on 31 December 2025, companies in scope will still need to publish their CSRD-aligned sustainability statement in 2026 (based on 2025 data).
- The European Commission has announced they intend to simplify CSRD requirements.
A first draft of what these simplifications might look like is currently expected for the end of February or the beginning of March. Then, a legislative process, where an agreement between the 27 EU member states and the European Parliament must be reached, will follow. This political process can take several months; sometimes even years.
So what is currently speculation?
- Timings
As of today, The European Commission plans to issue proposals for the Sustainability Omnibus during Q1 2025, but we cannot be sure on which date exactly. 26 February has been mentioned as a possible date, but there might be delays. And when will the legislative process be finalised, and any changes be enforced? It’s very important to stress that there has been no formal commitment to any deadlines, and all timings are purely speculative at this stage.
- And everything else…
What exactly will change in terms of who will have to report when, and on what, is simply not clear today. It is crucial to note that there has been no formal confirmation of what the changes will entail, and all potential revisions remain purely speculative at this stage. Position Green as a business has been adapting to regulatory shifts since 2015, and many of our in-house advisors have been coaching businesses through regulatory changes for much longer. In our experience, it’s better to focus on the facts. Our experts continuously monitor the regulatory landscape, and we take action when it’s clear what is needed.
“It’s really important for companies not to fall behind on their sustainability journey. Regulations may change, but your ability to drive sustainable business growth doesn’t. Actionable non-financial data is essential for any business to thrive, regardless of the political debate.”
Julia Staunig – Chief Strategy Officer, Position Green
So what does this mean for your ESG reporting?
In essence, currently not much. Even if EU laws change, compliance is just one piece of the puzzle — high-quality ESG data is essential for strategic decision-making, customer relationships, investor expectations, and long-term business resilience.
We recommend companies continue with their CSRD preparations based on the current legal framework while keeping implementation flexible, prioritizing what’s strategically important, and adopting a “beyond compliance” mindset. It’s also highly unlikely that EU laws will be scrapped altogether. Even if they were, it would only present a bigger opportunity for companies with data-driven sustainability strategies to make further competitive gains. Plus, postponing ESG reporting efforts is likely to cause major headaches in the long run as companies need to catch up later.
Drive impact beyond compliance. Be prepared for whatever EU regulations come your way with ESG reporting software designed by real experts.
- Stay a step ahead with flexible ESG software: seamlessly adapt to any regulatory needs as they unfold with Position’s Green modular software platform
- Get unmatched support: with the largest and most experienced advisory team in the sustainability software industry, our experts are here to guide you and keep your platform continuously updated
Julia Staunig
Chief Growth Officer
Position Green
