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Overview

In response to Mario Draghi's report assessing the competitiveness of the EU, the Commission developed the Omnibus Initiative. This initiative comprises a series of legislative packages designed to simplify and harmonize specific regulatory frameworks within the EU.

The first package focuses on streamlining both existing and forthcoming sustainability reporting and due diligence obligations, while maintaining alignment with the EU's economic, social and environmental objectives. Since the launch of the initiative, the Commission has enacted several directives, including the "Stop-the-clock" Directive and the "ESRS Quick-Fix", which introduce targeted amendments to sustainability reporting requirements. Most notably, in February 2026, the Commission formally adopted the Omnibus I Directive, which significantly narrows the scope and reduced reporting requirements associated with multiple EU sustainability reporting mandates.

This article seeks to provide a comprehensive overview of the key legislative changes arising primarily from Omnibus package I, while also incorporating relevant modifications into each specific section of the legislation.

CSRD

• Stop-the-clock: 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).

• Scope: The thresholds for mandatory reporting have been set at 1,000 employees and net turnover of EUR 450 million (also for insurance and credit institutions). These criteria are consistently applied to the SFDR and Taxonomy Regulation. Furthermore, certain financial holding companies are exempted from consolidated reporting under specific conditions, and listed SMEs are now longer within the scope of the CSRD.

• Value Chain Cap: Information requests from undertakings with fewer than 1,000 employees are limited to the data covered by the Voluntary Standards for small and medium-sized enterprises (VSME)

• 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 sustainability reports 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: Following the ESRS Quick Fix, which allows undertakings to omit certain datapoints in their reporting, the Omnibus I Directive sets out a substantial revision of the ESRS within the next months. The goal is to prioritize quantitative datapoints and meaningful metrics and further distinguish clearly between mandatory and voluntary datapoints.




• 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

• Scope: The new threshold for mandatory application of due diligence obligations is set at 5,000 employees and net turnover of EUR 1.5 billion.

  • For companies that have entered into franchising or licensing agreements the threshold for royalties is raised to EUR 75 million and EUR 275 million for turnover. 

  • Non-EU companies with more than EUR 1.5 billion turnover in the EU are also in scope of the CSDDD

  • In addition, there will be no more staggered entry. For all companies in scope, the CSDDD becomes mandatory as of July 2029.

• 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.

Sources

• Limberg, N., Pfanner, S., 2025. Eine kritische Würdigung des ersten Omnibus-Vereinfachungspakets (Teil 1). Zeitschrift für Recht und Rechnungswesen (2025/24)

• Limberg, N., Pfanner, S., 2025. Eine kritische Würdigung des ersten Omnibus-Vereinfachungspakets (Teil 2). Zeitschrift für Recht und Rechnungswesen (2025/27)

• EUR-Lex, Stop-the-Clock Directive 

• EUR-Lex, Content Proposal

• Delegated Regulation COM/2025/4812

• Delegated Regulation COM/2025/4568