As announced in previous press releases, the “Omnibus” package aims at improving consistency and simplifying transparency rules on environmental, social and governance (ESG) issues. This set of proposals – commonly referred to as the “Omnibus” package – covers several key European regulations, namely the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), the EU Taxonomy Regulation and the Carbon Border Adjustment Mechanism (CBAM). The “Omnibus” package thus aims at making the CSRD more accessible and less burdensome for companies, while preserving its ambition for transparency. This proposal stems from concerns raised by the complexity of the CSRD’s implementation.

The main substantive changes proposed by the “Omnibus” package are summarised below:

Scope – proposals to amend the thresholds of the CSRD

It is proposed to adjust the thresholds of the CSRD: if adopted, the new requirements will apply to large undertakings, parent undertakings of a large group, and listed small and medium-sized undertakings with more than 1,000 employees and either a turnover exceeding €50 million or a total balance sheet exceeding €25 million.

Two-year postponement for large companies and parent companies at the head of a large group, as well as for listed small and medium-sized companies, which will now have to prepare and publish (consolidated) sustainability information from 2027 (filing and publication in 2028) instead of from 2025 (filing and publication in 2026). As mentioned above, this proposal was adopted by the co-legislators on 14 April 2025 (Directive (EU) 2025/794, known as the ‘Stop-the-clock’ Directive).

The “Omnibus” package also proposes an alternative for undertakings not covered by the CSRD. In this case, these undertakings should be able to publish their sustainability information on a voluntary basis using a voluntary standard to be adopted by the European Commission and based on the voluntary standard for small and medium-sized undertakings (Voluntary Reporting Standard for SMEs) developed by EFRAG.

Proposed amendment to the thresholds applicable to non-European undertakings

The “Omnibus” package also proposes to amend the thresholds applicable to non-European undertakings covered by the CSRD provisions.

If the proposed measures are adopted, the following would be covered:

1) Undertakings that have directly generated net turnover of more than €450 million in the EU in each of the last two consecutive financial years

and

2) that have either i) a subsidiary categorised as a large undertaking or ii) a branch with net turnover of at least €50 million in the EU in the previous financial year.

Luxembourg subsidiaries or branches are responsible for publishing the sustainability report of their parent undertaking whose registered office is based in a third country.

Proposal to revise the delegated act on ESRS standards

On the one hand, the Commission proposes to update the ESRS standards. This proposed revision aims primarily at reducing the number of data points, clarify ambiguous provisions and ensure consistency with other legislation. On the other hand, after several postponements, the European Commission proposes to abandon the project to adopt sector-specific ESRS standards.

Introduction of a “value chain cap“

The “Omnibus” package also proposes to introduce a “value chain cap”. The aim of this measure is to protect undertakings with fewer than 1,000 employees involved in the value chain of an undertaking falling within the scope of the CSRD by limiting the information that undertakings within the scope of the CSRD will be entitled to request from them to only that contained in the VSME standard.

Assurance

The “Omnibus” package proposes to remove the proposed transition from a limited assurance requirement to a reasonable assurance requirement. The Commission also commits to publish targeted guidelines on assurance to address issues that have already arisen and are likely to result in additional burdens for undertakings.