CSRD Omnibus Update

Introduction

The EU’s sustainability reporting landscape has evolved rapidly over the past few years, with overlapping regulations and complex timelines. On 26 February 2025, the European Commission launched the “Omnibus Package” to simplify, align, and rationalise these rules. This blog post chronicles this evolution, summarises where the implementation of CSRD, CSDDD, and the EU Taxonomy currently stands – and what the simplification drive means for companies and the broader goal of sustainability transparency. 

For more detailed information, download our White Paper on this topic. 

Background

The EU sustainability framework comprises several pieces of legislation, which are broadly under the following categories:

• Corporate Sustainability Reporting Directive (CSRD)
• EU Taxonomy Regulation and Delegated Acts
• Corporate Sustainability Due Diligence Directive (CSDDD)
• Sustainable Finance Disclosure Regulation (SFDR)

The first two are interlinked. CSRD is about transparency and reporting. It creates the obligation for companies to disclose sustainability information. The EU taxonomy is a classification system which sets the criteria for classifying which activities are “environmentally sustainable”. 

Together with the European Sustainability Reporting Standards (ESRSs), as published by EFRAG, they introduce detailed standardised reporting on Sustainability. 

The CSDDD is more about action and accountability. It requires process-driven due diligence. It requires large companies operating in the EU to identify, prevent, mitigate and remedy adverse human rights and environmental impacts in their operations and value chains.  

We exclude SFDR from this analysis as relates to financial market participants only, and it is not directly impacted by the Omnibus package proposals. 

It is worth noting that CSRD and CSDDD are directives, which means they need to be transposed by EU members states into national legislation before they become effective, whereas the EU Taxonomy is a regulation which means that it automatically applies to all members states without the need for transposition. 

By the end of 2024, the above framework was fully in place, fully enacted, and ready for over 50,000 undertakings to implement (not including an estimated 10,000 additional ‘third country’ companies). 

All the above legislations were to be implemented in phases or ‘waves’ between 2025 and 2030.

Digitisation

Digitisation is central to the EU’s transparency goals: structured, machine-readable sustainability data enables comparability, automation, and assurance. The CSRD and the EU Taxonomy are required to be reported in Inline XBRL Format under the EU’s European Single Electronic Format Regulation. 

The CSRD does not specify a separate timetable for the introduction of this digital requirement, so it would be reasonable to assume the format is required from the outset, in line with the Tallinn Declaration on eGovernment’s digital-by-default principle. 

However, when the European Securities and Markets Authority (ESMA) published their “Consultation Paper on ESEF RTS – marking up rules for sustainability reports and financial notes and EEAP RTS amendments“ on 13 December 2024, they proposed a different timetable for digitisation. This was dependent on the publication date of the revised RTS in the Official journal:

The digitisation requirement, including use of the ESEF/iXBRL format, is not affected by the Omnibus proposals. Digitisation is still high on the EU agenda and enhances the utility of all the data collected through sustainability reporting requirements. The Omnibus does, however, include a clarification that until the rules on the marking up of sustainability reporting are adopted by way of a Delegated Regulation, undertakings should not be required to mark-up their sustainability reporting. 

The Omnibus package proposals

A combination of various factors, including shifting politics, industry and business lobbying and a concern by policymakers that additional reporting burdens could undermine EU competitiveness, led to the EC publishing a proposal in June 2023 for streamlining and aligning reporting requirements for ESG reporting. The EC published a new package of proposals on 26 February 2025, aiming to simplify the rules on sustainability.  

The Omnibus package has several components: 

• a ‘stop-the-clock’ Directive aimed at postponing the reporting requirements for waves 2 and 3 of CSRD by two years
• a proposed Directive with substantial simplification amendments for CSRD and CSDDD
• a proposed Delegated Regulation amending the EU Taxonomy Regulation and Delegated Acts

Separately to the Omnibus package proposals, on 11 July 2025, the EC adopted the ‘quick-fix’ Delegated Act which modifies the original requirements of the ESRS standards so that Wave 1 companies that have already been through the first step of the implementation, do not have to move on to the subsequent stages which step up the disclosure requirements while the simplification proposals are making their way through the legislative process. 

Threshold of proposed amendments to CSRD and CSDDD (COM(2025)81)

CSRD proposed amendments

A key proposed change for CSRD, was to increase the number of employees threshold from 250 to 1000. This was estimated to reduce the undertakings within the scope of CSRD by 80%. 

As part of the proposals, the Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG-FISMA) requested from the European Financial Reporting Advisory Group (EFRAG) to revise the European Sustainability Reporting Standards (ESRSs) and substantially reduce the number of mandatory data points. They were to do this by following a set of general recommendations, but without undermining the interoperability with global reporting standards and without compromising the principle of materiality assessment for each undertaking. 

In April 2025, EFRAG published their proposed amended ESRSs. The following ‘levers’ were followed to identify areas of simplification:

• a simplified double materiality approach
• better readability of the resulting disclosures
• linking Minimum Disclosure Requirements (MDRs) to the topical standards, and renaming them to General Disclosure Requirements (GDRs)
• restructuring the standards themselves to achieve better understandability
• introducing a number of burden reduction reliefs
• enhanced interoperability with other global sustainability reporting frameworks

EFRAG was successful in reducing the number of data points derived from the ESRSs by 68%. In practice, only a small proportion of the data points removed would have been used by each undertaking. After a consultation period, EFRAG is now working through the feedback and aims to finalise the revised ESRS by 30 November 2025. 

For a more detailed analysis of the above changes see our full White Paper. 

CSDDD proposed amendments

For CSDDD the Omnibus proposes: 

• A postponement of deadlines
• Retaining scope thresholds
• Reducing the scope of due diligence obligations
• Narrower definition of ‘stakeholder’
• A more ‘risk based’ approach for risk identification and assessment
• Reduced frequency of monitoring/reviewing due diligence measures
• Restrictions to Member States on introducing further local requirements on sustainability due diligence

Note that the European Council’s (EUCO) negotiating position on this is to raise the thresholds from 1000 to 5000 employees and from €450m to €1.5 billion net turnover.   

Other proposed amendments

The proposals also amend the Audit Directive and the Accounting Directive. For audit, it removes the EC’s empowerment to eventually move from a limited assurance to a reasonable assurance requirement. The Accounting Directive is changed to reflect the new proposed thresholds for reporting under CSRD and CSDDD as well as to give companies with more than 1000 employees but less than €450m turnover more flexibility when reporting under the EU Taxonomy Regulation.

Current status of the above proposals for CSRD and CSDDD

The latest update on where the COM(2025)81 amendments are in the EU legislative process is that the EC and the EUCO have locked-in their negotiating positions for the trialogue discussions. The EC, as it initially proposed, favours an increased threshold to more than 1000 employees for the requirements of CSRD disclosures. The EUCO agrees with this threshold but also proposes an additional threshold of €450m turnover which will align the reporting thresholds with those of CSDDD.  

The European Parliament (EP) approved its negotiating position in a vote on 13 November. The main amendments that they are proposing include a threshold of 1,750 employees or more, an additional €450m turnover threshold, as well as exemptions for listed subsidiaries and financial holdings. In addition to the cap imposed for requests from the value chain to the extent of VSME disclosures, the EP also proposes using the same thresholds of 1,750 employees and €450m turnover for the entities the requests are made from. 

The trialogue negotiations between the three EU institutions have already started. They are aiming to conclude the negotiations in early December 2025.

EU Taxonomy Regulation

The EC published a consultation on 26 February 2025 for a delegated regulation to amend the Taxonomy Disclosures Delegated Act, the Taxonomy Climate Delegated Act and Taxonomy Environmental Delegated Act. This was finally adopted by the EC on 4 July 2025 and was submitted to the EP and the EUCO for review (a four + two months scrutiny period).  

The aim is for it to apply from 1 January 2026, covering the 2025 financial year, but with the companies given the option to opt to defer its application for another year. 

The main changes proposed to the EU Taxonomy Regulation are: 

• Materiality thresholds have been introduced
• The Do-No-Significant-Harm (DNSH) criteria are simplified
• Streamlined Reporting Templates (reduced number of tables and data points)
• Opt-out option for financial companies for a transitional period of two years
• Option to defer implementation by one year
• General improvements to clarity, usability, consistency and support for transition planning

For a more detailed analysis of the above changes, see our full White Paper.  

Opinion 

An initial observation with respect to the simplification project is that some of the original objectives of the EC are not necessarily met. The simplified sustainability regulatory environment does not seem to address the shortcomings of NFRS, as it appears that fewer undertakings will have to report under CSRD. Therefore, it arguably does not support investor and stakeholder decision-making to the extent that was originally envisioned.

Nevertheless, the original agreed position of the above legislations perhaps went too far and therefore a simplification was inevitable. The original framework placed a significant burden on many undertakings and their value chains. CoreFiling is glad to see the simplification project approaching a conclusion and applauds the efforts of the various EU bodies involved as well as the efforts of EFRAG. These measures will recalibrate the EU’s sustainability reporting regime towards proportionality, clarity and competitiveness.

Importantly, at CoreFiling we see the simplification of the reporting requirements as an opportunity. With reporting burdens reduced, the EU now has a unique opportunity to accelerate the move to digital-by-default sustainability reporting, ensuring that structured data empowers investors, regulators, and AI-driven analysis alike.  

Our full White Paper on the Omnibus proposals includes a clear timeline of events of the Omnibus process so far and a summary of the changes along with where to track the various proposed pieces of legislation. The summary includes information about which existing pieces of the legislation are being impacted and information about where each legislative instrument currently is in the process.