Quick Summary:
On November 13th, 2025, the EU Parliament adopted the Omnibus I Directive, a package of changes designed to streamline sustainability reporting amid concerns that existing requirements were too costly and burdensome. The measure was passed with 382 votes in favour, 249 against, and 13 abstentions.
The reforms affect two key EU laws: the CSRD (Corporate Sustainability Reporting Directive) and the CSDDD (Corporate Sustainability Due Diligence Directive). Key changes include raising the CSRD reporting threshold from 250+ employees to 1,000+, making sector-specific standards voluntary, and removing mandatory climate transition plans. The goal: reduce administrative burden, cut costs, and improve EU competitiveness while focusing obligations on the largest companies.
What does the EU Omnibus I mean for sustainability reporting?
In EU lawmaking, an "omnibus" is a mechanism for amending multiple directives or regulations at once, rather than introducing separate laws.
Omnibus I updates and simplifies two major sustainability frameworks:
•CSRD (Corporate Sustainability Reporting Directive, EU 2022/2464): Requires companies to report annually on sustainability impacts, including all greenhouse gas emissions – Scope 1 (direct), Scope 2 (indirect from energy), and Scope 3 (other indirect, including supply chain and business travel).
•CSDDD (Corporate Sustainability Due Diligence Directive, EU 2024/1760)): Requires large companies to address human rights and environmental risks across operations, subsidiaries, and value chains, align with Paris Agreement goals, and report publicly.
Both directives were originally introduced to drive corporate accountability, but businesses and policymakers raised concerns about complexity, cost, and feasibility, prompting this simplification.
What’s changed after the EU Omnibus I?
The Omnibus I introduced major simplifications to CSRD and CSDDD, reshaping who must report and what they must disclose.
We’ve listed them below, so you can get the full picture:
CSRD Changes:
Category | Before Omnibus I | After Omnibus I | Impact |
Who reports | Companies with 250+ employees and €40m+ or €20m+ assets | Companies with 1,000+ employees and €50M+ revenue or €25M+ assets | Mid-sized companies dropped from scope |
Sector-Specific Standards (ESRS) | Mandatory (for applicable sectors) | Voluntary | Simpler reporting; fewer rules |
Climate Transition Plans | Mandatory (Paris-aligned) | Voluntary | Reduced burden |
Data Points & Disclosures | Extensive granular requirements | Reduced qualitative emphasis | Lower admin load |
CSDDD changes:
Category | Before Omnibus I | After Omnibus I | Impact |
Who reports | 1,000+ employees and €450m turnover | 5,000+ employees and €1.5B+ net turnover | Mid-sized companies dropped from scope |
Supply Chain Due Diligence Scope | Full supply chain due diligence required | Due diligence only required for direct partners & subsidiaries | Companies no longer need to assess risks from indirect or remote suppliers |
Materiality assessment | Required | Still required | Companies must continue to identify which human rights and environmental impact are most relevant to their operations. |
Assurance | Required | Still required | Independent verification of reporting remains mandatory |
Omnibus I may lighten the reporting load but the value of high-quality emissions data stays the same. It's still essential for meeting climate targets, satisfying investors, and making informed business decisions.
Who still has to report under CSRD and CSDDD?
Following Omnibus I, mandatory CSRD and CSDDD reporting thresholds have increased, removing most mid-sized companies from scope. Only the largest EU and certain non-EU companies must report, while smaller firms can opt in voluntarily.
Who still has to report under CSRD:
•Large EU companies: 1,000+* employees and €50M+ revenue or €25M+ assets
*(The EU Parliament has proposed raising this to 1,750 employees, so it could be subject to change following trilogue negotiation)
•Listed SMEs: Small and medium enterprises listed on EU markets follow simplified ESRS-LSME standards, with later deadlines.
•Non-EU parent companies: Must report if they generate €150M+ EU revenue and have a significant EU presence.
•Existing reporters: Largest “public interest” companies (500+ employees) already under NFRD rules.
Who still has to report under CSDDD:
•Large Companies: 5,000+ employees and €1.5B+ net turnover.
•Non-EU companies: Must report if they generate €150M+ EU revenue and a significant EU presence (see FAQs for criteria).
Reporting obligations and deadlines vary by company size and type, with larger companies required to report earlier than SMEs or smaller firms.
When Do I Have to Report Under CSRD and CSDDD?
The CSRD and CSDDD rollout is happening in multiple "waves," each affecting different company sizes and reporting years.
CSRD Reporting Timeline:
Wave 1: Already Reporting (First report in 2025)
•Public interest entities with 500+ employees, already under the NFRD, began reporting in 2025 for the 2024 financial year.
*Note: Omnibus I delays do not apply to this wave.
Wave 2: Large Companies (First report in 2028)
•Companies with 1,000+ employees AND €50M+ revenue or €25M+ assets report for the first time in 2028, covering the 2027 financial year. This wave was postponed by two years.
Wave 3: Listed SMEs (First report in 2029)
•Listed SMEs report for the first time in 2029, covering the 2028 financial year, using simplified standards. A 2-year delay option means some may not publish until 2030.
Non-EU Companies (First report in 2029)
•Non-EU companies with €150M+ EU revenue report from 2029 at the group level. Their EU subsidiaries may report earlier if they meet Wave 2 or Wave 3 thresholds.
Not sure which CSRD wave applies to you? Use our tool to calculate your specific CSRD reporting deadline.
CSDDD Reporting Timeline:
The new due diligence rules require companies to reduce their negative impact on people and planet. EU member states have an extra year, until 26 July 2027, to put these rules into national law.
Wave 1: Large Companies (First report in 2028)
•EU firms with 5,000+ employees and €1.5 billion+ turnover, and non-EU companies meeting the same EU turnover threshold report for the first time in 2028, covering the 2027 financial year.
Wave 2: Mid-Large Companies (First report in 2028)
•EU companies with 3,000+ employees and €900 million+ turnover, and non-EU companies meeting that EU turnover, report for the first time in 2028, covering the 2027 financial year.
FAQs:
What Should Businesses Now Out of Scope Do?
Most smaller or medium-sized EU companies, those with fewer than 1,000 employees and below €50M revenue or €25M assets, are now outside mandatory CSRD reporting. Being out of scope lifts the administrative weight, but it doesn’t remove the value of comprehensive sustainability data. Here’s how smaller companies can stay aligned and use this moment to their advantage:
•Report voluntarily: Follow the European Sustainability Reporting Standards (ESRS) for credible sustainability reporting. The ESRS provides a common framework and guidelines for sustainability reporting across the EU, helping companies disclose consistent, comparable, and high-quality information.
•SMEs: Consider using The Voluntary Sustainability Reporting Standard for SMEs (VSME). The VSME framework is a flexible ESG reporting framework, endorsed by the European Commission, to help small and medium-sized enterprises respond efficiently to sustainability information requests without the burden of full CSRD compliance.
•Reinvest compliance budget: Focus on real sustainability actions, such as improving energy efficiency, adopting renewable energy, greening supply chains, or enhancing employee engagement.
Are CSRD and CSDDD requirements and timelines still subject to change?
Trilogue negotiations between the European Parliament, Council, and Commission began on 18 November 2025 to finalise the legal text, hopefully reaching an agreement by the end of 2025.
Once agreed, the revised CSRD and CSDDD rules will be published in the Official Journal of the EU, and member states will have 12 months to transpose them into national law.
While the overall direction (simplified reporting for fewer, larger companies) is clear, some details such as reporting thresholds, obligations, or exact deadlines could still see adjustments during these negotiations.
How does the EU Omnibus I affect Non-EU/UK companies?
Non-EU/UK businesses don’t automatically report under CSRD/CSDDD, but must if they:
•Have an EU subsidiary meeting threshold (1,000+ employees or €50M+ revenue)
•Generate €150M+ EU revenue (from 2029)
•Are listed on an EU market
Companies outside these criteria can choose to report voluntarily to simplify EU operations and meet investor expectations.
What are the penalties for non-compliance?
Liability rules will be set at the national level rather than the EU level. However, the European Parliament has drafted a cap on how far national liability rules may go, acting as a maximum limit to preserve EU-wide harmonisation.
•CSRD: Member states set penalties, including fines, public disclosure of non-compliance, or limits on public procurement/EU funding
•CSDDD: Fines capped at 5% of net worldwide turnover (or parent company consolidated turnover)
How can businesses meet the new CSRD and CSDDD reporting requirements?
Navigating evolving EU sustainability rules can be complex. The right tools can help simplify reporting:
•EU Digital Reporting Portal: Access free templates, guidance, and all EU sustainability reporting requirements via ESAP.
•Dedicated Compliance Tools: Solutions like our Compliance Suite streamline reporting with step-by-step regulation checklists and assurance-ready data exports.
Next steps for your business:
While the Omnibus I Directive simplifies and reduces mandatory reporting scope, the need for transparent, high-quality sustainability data has not disappeared. Investors, consumers, and business partners will continue to demand this information.
If you need support navigating what this means for your organisation, reach out to our Advisory Team.
Sources:
•EU Parliament Press Release: MEPs Approve CSRD & CSDDD Simplification (6 Nov 2025)
•Final Adopted Text of Omnibus I Amendments to CSRD & CSDDD (15 Nov 2025)
•Council Summary Including CSRD and CSDDD Amendments
This guide is for informational purposes only and does not constitute legal advice. Organisations should seek professional legal advice to ensure compliance with applicable laws and regulations specific to their operations.