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.

On 9 December 2025, the EU Council and the European Parliament reached a provisional agreement on the Omnibus package simplifying the CSRD. The Parliament approved this agreement on 16 December 2025. The final text still has to be formally approved by Council. The directive amending the requirements will enter into force twenty days after its publication in the Official Journal.

Companies employing on average over 1,000 employees and with a net annual turnover of over €450 million will remain within the scope of the CSRD. The first CSRD reports (those from ‘wave 2’ companies) are expected in 2028 and will cover the 2027 financial year.

Non-European groups will only be required to provide a CSRD report if they exceed €450 million net turnover generated in the EU and have at least one EU subsidiary or branch with over €200 million net turnover, beginning in FY28 (reporting in 2029). Reporting standards for non-European companies are not expected until October 2027 at the earliest.

Financial holding companies will be exempt, but their subsidiaries or sub-groups may still be required to report if they meet the threshold for application.

All companies, including publicly traded public-interest entities (PIE), will be eligible for group exemption if they are included in a consolidated sustainability report.

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 ESRS are being revised with the aim of substantially reducing the number of data points, clarifying provisions deemed unclear and improving consistency with other pieces of legislation. The delegated act revising the first set of ESRS is expected to be adopted in the first half of 2026. EFRAG has published in December 2025 the draft simplified ESRS.

The obligation for the Commission to adopt sector-specific standards is removed.

The requirement to adopt standards for reasonable assurance has been removed.

The adoption of delegated acts in order to provide for limited assurance standards is postponed to 1 July 2027 at the latest.

For the audit profession, the final Omnibus I text makes it clear that audit firms that want to provide sustainability assurance services only need to appoint at least one key sustainability partner who meets the requirements for approval for this purpose and is approved as a statutory auditor in the Member State concerned. It is therefore no longer required for the firm to be approved to carry out these services.

This text also provides for simpler registration conditions and an exemption from supervision for third-country auditors.