What does the EU’s sustainability omnibus mean for the CSRD and your sustainability 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).

Key changes under consideration

The sustainability omnibus package cover proposed changes, with final decisions that are pending:

• Corporate Sustainability Reporting Directive (CSRD)
• Corporate Sustainability Due Diligence Directive (CSDDD)
• EU Taxonomy on Sustainable Economic Activities
• and possibly other related laws

The latest

• CSRD scope and timeline: Only companies with 1,000+ employees and either a turnover above EUR 50 million or a balance sheet above EUR 25 million. Large unlisted companies and listed SMEs may receive a two-year reporting delay.
• Reporting simplifications: Proposed changes include fewer data points, removal of sector-specific ESRS, and limited assurance retained instead of transitioning to reasonable assurance. Double materiality remains unchanged.
• CSDDD adjustments:The CSDDD deadline may move to 2028, with due diligence limited to direct suppliers.
• EU Taxonomy adjustments: Taxonomy reporting would apply only to CSDDD-scope companies (companies with 1,000+ employees and €450M+ turnover), with simplified templates and streamlined Do No Significant Harm (DNSH) criteria.
• ESG data requests for SMEs: A voluntary SME reporting standard (VSME) would serve as the basis for ESG data collection from business partners and suppliers 

What’s next?

The European Parliament and Council will discuss and adopt any changes. The timeline? Uncertain. Some political battles are likely. Some elements, for example the delay in the timeline of the CSRD, might be adopted quicker than other proposed changes. Once adopted, national transposition follows. 

Our recommendations

• If you are meet the above required thresholds, your reporting remains unchanged.
• If you fall below those thresholds but previously determined you are in scope to report in 2025 on 2024 data, we recommend to continue in the process. These updates are still in proposal phase, and therefore may not pass by the time reports on 2024 data are due and you run the risk of non-compliance.
• If you are planning to report in 2026 on 2025 data, continue collecting data as planned given current proposal phase of Omnibus. Pending decisions from EU and any gaps that exist in the company’s available data, the 2026 report can be reported ‘with reference’ to ESRS rather than fully aligned, providing flexibility and extended timelines for operationalizing ESRS requirements while still being in compliance.
• The double materiality assessment is still the standard and could serve as a license to operate in the EU market, therefore we still recommend all companies with business in EU carry out a DMA process aligned with CSRD.
• Given that the VSME standards will be necessary for business activity in the future, this will be the foundational document to consult to better understand which topics and metrics to report on based on DMA results.

“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. 

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