Omnibus package

On 26 February 2025, the Commission adopted a package of proposals (Omnibus package) to simplify EU rules and boost competitiveness. Among other things, the package proposes to apply the CSRD only to the largest companies, focusing the sustainability reporting obligations on the companies which are more likely to have the biggest impacts on people and the environment. Moreover, it seeks to ensure that reporting requirements on large companies do not burden smaller companies in their value chains.

The main planned impacts of the Omnibus package regarding the CSRD requirements are summarised below. These are proposals from the Commission and are subject to the agreement of the co-legislators. The details of the proposals are available on the website of the Commission.

The Commission proposes to reduce the scope of reporting companies to the largest undertakings: The CSRD reporting requirements would only apply to large undertakings with more than 1,000 employees (i.e. undertakings that have more than 1,000 employees and either a turnover above EUR 50 million or a balance sheet total above EUR 25 million).

Large undertakings with more than 1,000 employees that do not have to report in 2025 (i.e., not public interest entities) would benefit from a two-year postponement of the entry into application of their reporting requirements. They would report for the first time in 2028 for FY 2027.

Companies not in scope of the revised CSRD (< 1,000 employees) may choose to report voluntarily on the basis of a simplified voluntary standard to be adopted by the Commission, based on the voluntary reporting standard for SMEs (VSME) developed by EFRAG.

A ‘value chain cap’ will protect companies in the value chain with no more than 1,000 employees from the trickle-down effect, by limiting the information that undertakings in scope of the CSRD can request from them to information specified in the VSME standard.

The Commission also intends to revise the ESRS, with the aim of substantially reducing the number of data points, clarifying provisions deemed unclear and improving consistency with other pieces of legislation. The obligation to adopt sector-specific standards is removed too.

The proposal removes the possibility for the Commission to propose moving from a limited assurance requirement to a reasonable assurance requirement. The Commission is committed to issuing targeted guidelines on assurance to address emerging issues that may be generating unnecessary burden on companies.