What will the Omnibus proposal bring?

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On 26 February 2025, the European Commission presented a proposal for a new Omnibus Directive (Omnibus Simplification Package), which aims to streamline and simplify the administrative procedures for companies in sustainability reporting under the CSRD and the EU Taxonomy.

However, the Omnibus proposal should also affect the CSDDD, the carbon offsetting mechanism at borders (CBAM) or the enhancement of consumer protection and transparency of online markets.

The draft Omnibus Directive should significantly modify the reporting requirements under the CSRD for small and medium-sized enterprises (SMEs), which will be subject to the reporting obligation 2026 and 2027. It is for these enterprises that the draft Omnibus Directive should postpone the reporting obligation until 2028.

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What changes can be expected?

The reporting obligation would only apply to a selected "subset" of so-called large enterprises (with at least 1000 employees and a turnover of € 450 million);
there are no plans to develop sectoral standards in the area of reporting;
companies with up to 1,000 employees should not report more information when reporting value chain information than they would under the amended voluntary SME reporting standard or industry specific information;
postponement of the initial application by one year, reduction in the number of business partners and stakeholders to be considered and less frequent evaluations;
for non-EU companies, they would report information under the NESRS rules at group level from 2028, if applicable:
- € 450 million turnover in the EU and
- an EU subsidiary, or
- an EU office with a turnover of more than €40 million

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Overview of key changes in relation to each directive:

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Given that the Omnibus Directive is still only in draft form, we recommend that companies that are already subject to reporting obligations under the current legislation in 2026 should have this data ready for the so-called sustainability report. The draft Omnibus Directive still has a relatively long legislative process ahead of it, during which a number of comments may be accepted, and it is therefore difficult to predict its final form.

Once the final text of the Omnibus Directive Proposal has been approved and published in the EU Bulletin, Member States will have to introduce a two-year delay of the first reporting into national legislation until the end of 2025, with the content of the CSRD reporting to be implemented within 12 months of the entry into force of the Directive.

If you are unsure about ESG legislation, or need help with report preparation or subsidies for "green projects", we at the team at Lansky, Ganzger, Jacko & Partner, would be happy to help.

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