The European Commission unveiled the Omnibus package on February 26, 2025, introducing reforms to the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CSDDD), and Taxonomy regulations. The intention of this change is to simplify sustainability-related reporting obligations, but uncertainty remains.  

The EU Omnibus Package proposes significant simplifications to sustainability reporting and due diligence requirements, benefiting businesses of all sizes. If fully implemented, the proposals are expected to reduce annual administrative costs by approximately €6.3 billion and unlock €50 billion in public and private investments. A major focus is protecting SMEs from excessive sustainability data requests, and reducing the overall reporting burden on companies by significantly limiting the data points covered in the EU Taxonomy. 

Countries that have transposed the CSRD into national law

Currently, only 15 of the 27 EU member states have fully transposed the CSRD into national law. Germany, France, and the Netherlands have adopted legislation, while Sweden and Italy are nearing completion. However, countries like Spain, Poland, and Greece are still in consultation stages, risking inconsistent reporting deadlines and regulatory fragmentation.

Consequences of missing transposition deadlines

If countries fail to transpose the CSRD on time, they will face consequences like:

  • Infringement proceedings: The European Commission may initiate legal actions against non-compliant states, potentially leading to fines.
  • Legal uncertainty: Businesses operating in delayed jurisdictions may face confusion about their obligations and deadlines.
  • Competitive disadvantages: Companies in compliant countries could gain a market edge with established ESG frameworks.
  • Pressure on multinational supply chains: Non-European companies may encounter inconsistent reporting demands from EU clients.

Positions from key countries: Germany, France, and Sweden

Let’s take a look at what key countries like Germany, France, and Sweden are hoping for with these impending changes.

Germany: Push for broad scope reductions

  • Higher CSRD thresholds: Proposes excluding most mid-cap companies (250-1,500 employees, turnover < €1.5 billion) and limiting reporting to large enterprises (1,000+ employees, turnover < €450 million), potentially exempting 40,000 companies.
  • Implementation delay: Advocates for a 2-year postponement for mid-caps and SMEs.
  • Value chain cap: Supports limiting subcontractor reporting requirements to protect SMEs.

France: A balanced approach

  • Mid-cap category: Recommends a dedicated mid-cap standard (LSME) with simplified ESG disclosures.
  • Opposes scope reductions: Argues that excluding mid-caps could increase fragmented ESG data requests from clients.
  • Sectoral standards: Promotes voluntary sector-specific standards for 1-2 years before mandatory implementation.

Sweden: Focus on business competitiveness

  • Opposition to delays: Sweden opposes Germany's 2-year delay, emphasizing regulatory stability for businesses that have already invested in compliance.
  • Pro-standardization: Supports streamlined ESG reporting standards to reduce reporting costs and complexity.
  • Sectoral guidance: Agrees with France on sectoral standards but advocates for clearer guidance for SMEs.

Key changes in the Omnibus package

Here’s a look at the changes that the Omnibus package proposed:

  • A proposal for a directive amending the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD)
  • A draft delegated act amending the Taxonomy Disclosures and the Taxonomy Climate and Environmental Delegated Acts, subject to public consultation.
  • A proposal for a regulation amending the Carbon Border Adjustment Mechanism Regulation
  • A proposal for a regulation amending the InvestEu Regulation

EU Omnibus package: Before and after


Corporate Sustainability Reporting Directive (CSRD)

Before

After

Scope of reporting

Companies with 250+ employees, €50M turnover, or €25M balance sheet total

Companies with 1,000+ employees and either €50M turnover or €25M balance sheet

Sector-specific standards

Required sector-specific standards

Eliminated sector-specific standards

Reporting timeline

2026-2027

Postponed to 2028

SMEs in value chains

Could face indirect reporting burdens

Shielded by a ‘Value Chain Cap’

Assurance standard

Potential shift from limited to reasonable assurance

No longer moving to reasonable assurance


Corporate Sustainability Due Diligence Directive (CSDDD)

Before

After

Implementation deadline

Initial transposition deadline: July 2027

Postponed to July 2028

Due diligence scope

Comprehensive assessments of entire value chains

Only full due diligence beyond direct business partners if plausible risks are identified

Monitoring frequency

Annual updates on due diligence effectiveness

Assessment required only every 5 years

Liability rules

Harmonized EU civil liability rules

Defer to national civil liability rules

Stakeholder engagement

Comprehensive stakeholder engagement requirements

Streamlined engagement process


EU Taxonomy Disclosures

Before

After

Mandatory reporting

All large companies under CSRD must report Taxonomy alignment

Voluntary for companies with €50M+ turnover & <1,000 employees

Reporting complexity

Extensive reporting requirements

Reduced data points by 70%

Materiality threshold

All eligible activities must be assessed

Only activities covering 10%+ of turnover/assets require reporting

Green Asset Ratio (GAR)

All corporate exposures included in GAR

Banks can exclude exposures to non-CSRD companies

Partial taxonomy alignment

Not recognized

Companies can report partial progress towards alignment


Carbon Border Adjustment Mechanism (CBAM)

Before

After

Importer scope

Applies to all importers of CBAM goods

90% of small importers (182,000) exempted

Emissions coverage

100% of emissions tracked

Still covers 99% of emissions

Reporting complexity

Extensive emissions calculations & compliance steps

Simplified reporting, emissions calculation, and financial liability

Small importers

All importers subject to obligations

Exempt importers below 50 tonnes per year threshold

Anti-circumvention

Basic tracking in place

Strengthened anti-abuse mechanisms


InvestEU Regulation

Before

After

EU guarantee size

Fixed size

Increased by €2.5B to unlock more funding

Reporting requirements

Frequent, detailed reporting for all recipients

Reduced reporting frequency and exempting SMEs from some reports

Access to funds

Strict eligibility criteria

More flexible financing, unlocking €50B in investments

SME definition for financial products

Strict application of EU SME definition

Adjusted for more accessibility

Legacy program integration

Separate funding sources

Merges EFSI, InnovFin, and CEF into InvestEU for greater capital efficiency

How to prepare for global implications

The Omnibus package marks a pivotal shift in EU sustainability reporting, driving transparency and standardization across industries. Its reach will extend beyond the EU, shaping global ESG expectations and Prophix can help businesses navigate these global implications with ease. By centralizing ESG data from multiple systems and automating consolidation processes, Prophix ensures compliance with evolving EU standards while reducing administrative burdens. Its advanced analytics and interactive dashboards provide actionable insights, enabling organizations to align with global ESG expectations and maintain a competitive edge in an increasingly sustainability-focused market.

Discover the possibilities of ESG reporting with Prophix.

This post has been updated following the Omnibus announcement of the EU Commission on February 26, 2025.