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Omnibus Package

Omnibus Package

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Overview

In response to Mario Draghi's report investigating the competitiveness of the EU, the Commission developed the Omnibus Initiative. Consisting of two packages, the first one aims to simplify existing and upcoming sustainability reporting and due diligence requirements. In the first package, the "Stop-the-clock Proposal" has already been passed as a directive and addresses the time of adoption of the CSRD and CSDDD. The “Content Proposal” still has to be approved and is expected to be passed by fall 2025. On the other hand, the second package focuses on the EU’s investment programs. This article seeks to provide an overview about the main changes in sustainability reporting legislation resulting mainly from Package I. However, the relevant changes are also incorporated into each specific section of legislation.

September 2024Draghi Report on the future of European competitiveness
February 2025Proposition of Omnibus package I (Stop-the-clock Proposal (COM/2025/80) and Content Proposal (COM/2025/81)
April 2025Adoption of the Stop-the-clock Directive (EU/2025/794)
July 2025Adoption of delegated acts to revise the first set of ESRS (COM/2025/4812) and Taxonomy Regulation (COM/2025/4568)

CSRD

  • Time of application: The CSRD determines three groups for mandatory sustainability reporting, the first of which already must provide a sustainability report. The time of application for the second wave is now postponed by two years, i.e. beginning in 2028 reporting on the financial year 2027. For the third wave the time of application has been postponed as well by 2 years (leading to disclosure beginning in 2029), and the Opt-out option for SME’s has been cancelled.

  • Scope: The minimum threshold for employees in Wave 1 has been raised from 500 to 1,000, which leads to an estimated decrease of 80% in companies subject to mandatory reporting. Moreover, the condition to be a Public Interest Entity (PIE) is no longer included.

  • Value Chain Cap: Undertakings are restricted to demand solely information from business partners in their value chain, which is included in a voluntary standard.

  • Assurance: A transition from limited assurance to reasonable assurance is no longer foreseen. Instead, the Commission is working on guidelines for audituing sustainability reports.  

  • Reporting Format: The requirement to publish the report in the European Single Electronic Format (ESEF) is postponed until relevant requirements are passed by the Commission.

Find out more about the CSRD

ESRS

  • Scope: The Content Proposal foresees decreasing the amount of mandatory datapoints and prioritizing quantitative relative to qualitative information. In addition, undertakings with more than 750 employees are granted the same phase-in options as undertakings with less employees.

  • Sector-specific Standards: These standards will no longer be developed. Consequently, there will only be cross-cutting and topical standards.

  • SME Standards: Moreover, standards for listed SMEs will no longer be developed. Instead, affected undertakings shall adopt voluntary standards which are currently under development by EFRAG.

Find out more about the ESRS.

EU-Taxonomy

  • Scope: Undertakings are now subject to mandatory reporting if they have more than 1,000 employees and a net-turnover of more than 450 million EUR. Companies with less revenue have the possibility to opt-in, leading to disclosure of KPIs about revenue and capital expenditures. 

  • Materiality: Undertakings will only have to report on financially material activities. An economic activity is assumed to be immaterial if the cumulative value of immaterial activites make up less than 10% of the denominator of the respective KPI. Previously, the notion of materiality has not been included in the Taxonomy regulation.

  • Accuracy of KPIs: Financial undertakings exposed to counterparty undertakings only have to include those counterparties in the calculation of KPIs, which are subject to the CSRD and SFDR. For instance, this change would affect the calculation of the Green-Asset-Ratio (GAR).

Find out more about the Taxonomy Regulation.

CSDDD

  • Time of adoption: 

    • Wave 1: As of 26.07.2028 for EU undertakings with more than 3,000 employees and revenue of 900 million EUR worldwide

    • Wave 2: As of 26.07.2028 for third country undertakings with more than 3,000 employees and revenue of 900 million EUR in the Union 

    • Wave 3: As of 26.07.2029 for undertakings with more than 1,000 employees and revenue of 450 million EUR worldwide and all companies subject to Art. 2 Par. 1 & 2 in EU/2024/1760

  • Financial Undertakings will not be subject to the CSDDD anymore. However, the EC reserves it's right to review this status. 

  • Stakeholder Definition: Interest groups which are or could be directly affected by the undertaking's products, services or actions. 

  • Civil liability: The criteria for civil liability in the CSDDD will be deleted. Instead, each member state shall develop criteria for their national legislation and ensure enforcement. In addition, member states can choose whether they allow third parties (e.g. NGOs) representing harmed parties in court proceedings.

Find out more about the CSDDD.

CBAM

  • Scope: Transition from a value-based de minimis threshold of 150 EUR per import to a weight-based threshold of 50 tons per year for mandatory application.  

  • Administrative Efficiency: Simplification of authorisation procedures and data collection processes.

Find out more about the CBAM.