The Omnibus I proposal, presented by the European Commission on 26 February 2025 within its broader “Simplification Package,” was proposed to streamline the implementation of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
After the conclusion of lengthy EU-level neobtainediations, Directive (EU) 2026/470 was published in the Official Journal of the EU on 26 February 2026. The new Directive is narrowing down the scope of both the CSRD and the CSDDD.
More specifically:
- due diligence requirements in the CSDD apply to companies exceeding both 5,000 employees and €1.5 billion net turnover, including certain franchising arrangements and third-countest companies meeting specific EU turnover thresholds.
- sustainability reporting requirements under the CSRD, companies exceeding both 1,000 employees (on average during the financial year) and €450 million net turnover would be eligible to comply with the rules.
The new rules entail further simplification elements, beyond narrowing down the scope. The European Financial Reporting Advisory Group (EFRAG) is currently in the process of preparing a simplified European Sustainability Reporting Standards (ESRS) for companies in scope of the CSRD to utilize. Meanwhile, from the CSDDD perspective, there is more flexibility for companies to identify adverse impacts, and determine these based on reasonable available information.
Two key provisions are no longer part of the law, and consequently alleviating company’s obligations in this context: (i) the previous obligation for companies in scope to develop transition plans for climate alter mitigation, and (ii) the EU harmonised liability regime.
Next steps:
- The Directive amfinishing CSRD and CSDD will enter into force on 18 March 2026.
- The obligations stemming from the CSRD will start applying from 19 March 2027, the transposition deadline for Member States
- The CSDDD transposition deadline is set for 26 July 2028. However, companies in scope will only necessary to comply with the rules by July 2029.
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