Omnibus package: how sustainability obligations for companies change
The Omnibus package Just presented marks an important update in the regulatory landscape on sustainability within the European Union.
In recent years, the EU has introduced numerous directives on sustainability, requiring companies to make a growing commitment to remain competitive and compliant with new regulations.
With the Omnibus package, which has yet to be finally approved by the Parliament and the European Council, Brussels aims to redefine the scope of application and simplify reporting obligations for companies, bringing together in a single document the 3 key regulations: the CSRD, the CSDDD And the EU taxonomy. In this way, the intention of the European Union is to balance the objectives of the Green Deal with the need to maintain market competitiveness.
What you'll find in this article:
- an summary table and immediate on the main points of the Omnibus package;
- Aanalysis of the regulatory environment where the package is inserted;
- The main changes introduced on CSRD, CSDDD, EU Taxonomy and CBAM.
We will also evaluate how these simplifications affect companies' sustainability commitments and whether they represent a real step forward or a weakening of existing regulatory instruments.
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The key points of the Omnibus package: summary table
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Regulatory context and Omnibus package: an evolving system for a more competitive market
The Omnibus package is part of a regulatory framework in constant transformation, where sustainability is becoming a central element in business strategies.
In recent years, the European Union has introduced key regulations such as Corporate Sustainability Reporting Directive (CSRD), which defines new reporting standards, the Corporate Sustainability Due Diligence Directive (CSDDD), which promotes greater responsibility along the supply chain, and the EU taxonomy, which guides investments towards sustainable activities.
These regulations are outlining a market increasingly oriented to transparency and sustainability, creating new opportunities for companies that choose to integrate these principles into their business model.
However, for this transition to be effective and accessible to everyone, it is necessary that the regulatory framework be structured in a way clear Ed efficient. It is precisely in this direction that the Omnibus package, with the aim of optimizing and making the application of existing regulations more linear.
The initiative aims to simplify obligations for companies, while at the same time keeping high sustainability standards, so as to guarantee a more favorable environment for investment and innovation.
The European Union aims to find a poise between achieving environmental objectives and market competitiveness, making sustainability a concrete advantage for companies that want to stand out.
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CSRD: the Omnibus package reduces reporting obligations
The Omnibus package proposes significant changes to Corporate Sustainability Reporting Directive (CSRD), with the intention of redefining the scope of application and simplifying reporting obligations for companies.
One of the most important aspects concerns the field of application of CSRD, with an increase in the mandatory thresholds. THEobligation to draw up the sustainability report will apply, according to the Omnibus proposal, only to companies with more than 1,000 employees and at least one of the other two dimensional criteria:
- 50 million euros in turnover;
- 25 million euros in net assets;
This review involves a drastic reduction in the number of companies involved, passing from more than 50,000 to less than 7,000 throughout the European Union.
Companies that were previously obliged (at least 250 employees and 50 million euros in turnover) to report starting from 2026 on 2025 data, should remain subject to the obligation only if they exceed 1,000 employees and, in any case, with a Delayed by two years.
This means that companies that should have published their first financial statements in 2026 according to the CSRD, according to the new proposal, will have to do so only in 2028, based on data from 2027.
Le companies with less than 1,000 employees they should no longer be subject to the obligation to report, but they may choose to join on a voluntary basis the VSME standard (Voluntary SME Standards), or a simplified scheme aligned with ESRS.
These standards, although not mandatory, may be particularly useful for SMEs, since the Omnibus package has Standardize information that banks, large companies subject to the CSRD and companies bound by the CSDDD can request from companies with less than 500 employees.
This information will be limited to the data provided for by the VSME voluntary standards, making the drafting of a VSME balance sheet a strategic tool to respond in a standardized and transparent way to ESG requests along the value chain. For companies with more than 500 employees, however, additional information may also be requested.
For many companies, drafting a sustainability report according to these standards could therefore facilitate compliance to the requests of customers, suppliers and credit institutions.
Another change concerns the review of the information provided in the sustainability reports. There should no longer be the gradual transition to “reasonable assurance”, a more in-depth review of the reported data. Companies, according to the Omnibus proposal, will instead remain subject to “limited assurance”, a less stringent level of verification.
Finally, the package proposes to introduce a simplification of ESRS, through a reduction in datapoints (required reporting KPIs). This intervention aims to make leaner and less onerous reporting for companies, eliminating some of the previously expected reporting indicators.
These changes represent a significant downsizing of the CSRD, with the aim of lightening the administrative burden for companies.
However, the reduction in the number of companies required to report, the postponement of certain measures and the elimination of 'reasonable assurance' raise Questions about the transparency and comparability of ESG information, fundamental elements for investors and stakeholders.
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CSDDD: a downsizing of corporate due diligence
The Omnibus package also intends to bring significant changes to Corporate Sustainability Due Diligence Directive (CSDDD), reducing the scope of application and simplifying obligations for companies.
In addition, the risk assessment involves no longer automatically including indirect suppliers, unless plausible information emerges that suggest a real risk.
Another substantial change concerns the Frequency of assessments along the value chain, which should now be carried out Every 5 years instead of annually, thus reducing regulatory pressure on supply chain management.
In addition, the information that companies subject to the CSDDD may request from suppliers will be differentiated according to their size:
- for companies with Maximum 500 employees, the information requested will be limited to the data provided for by the VSME standards;
- for companies with more than 500 employees, there is no regulatory limit on the information that may be requested.
A particularly controversial point is the expected removal of civil liability for companies that do not comply with due diligence obligations. This means that companies will no longer be able to be subject to legal sanctions in case of non-compliance.
As for the climate transition plans, according to the Omnibus package, companies will have to adopt them, but they will no longer be obliged to implement them, further reducing transparency on long-term sustainability commitments.
Another important aspect is the removal of due diligence obligations for the financial sector, which initially had to be included in the scope of the directive. In addition, the proposal Eliminate the provision of sanctions which established a minimum of 5% of global revenue for non-compliant companies.
The Omnibus package It also introduces a greater harmonization between member states, limiting the possibility for individual countries to adopt more stringent national regulations in key areas such as risk assessment, value chain due diligence, and sanctions.
The latest news concerns the Delay by one year in the application of the directive, with the entry into force scheduled for July 2027, so as to give companies more time to adapt to the new requirements.
These changes mark a Substantial downsizing of the CSDDD, reducing obligations for businesses and easing control over the supply chain.
While on the one hand this could simplify regulatory compliance, on the other hand, it raises Interrogatives on the real effectiveness of the directive in promoting a sustainable and responsible supply chain.
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EU taxonomy: towards a more flexible approach
With the Omnibus package, the application of EU taxonomy becomes voluntary for some categories of companies, marking a significant change of direction compared to the initial approach.
Companies subject to the CSRD with more than 1,000 employees, but with a turnover of up to 450 million euros, according to the Omnibus proposal will no longer be obliged to report their alignment with the Taxonomy, but they will be able to pick whether to adopt it or not.
Another change concerns the principle of “Do No Significant Harm” (DNSH), which until now has represented a pillar for determining the sustainability of an economic activity. With the new package, this principle comes weakened, making the criteria for evaluating whether an activity has negative impacts on other environmental objectives less stringent.
These changes aim to make the EU taxonomy more accessible and less expensive for companies, reducing the complexities related to reporting.
However, the choice to make it voluntary for some companies could affect transparency And on comparability of ESG information, creating a more fragmented framework for investors and stakeholders, who base their decisions on these parameters.
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CBAM: the Omnibus package redesigns the carbon adjustment mechanism
The Carbon Border Adjustment Mechanism (CBAM), in force since October 1, 2023, is the measure adopted by the European Union for Tax CO₂ incorporated into imported goods, with the aim of avoiding carbon leakage and ensuring conditions of fair competition between European companies and foreign producers.
After a first phase dedicated exclusively to reporting emissions (2023-2025), starting from January 2026, companies will have to purchase CBAM certificates, whose price will be aligned with that of ETS market.
With the Omnibus package, the European Commission has introduced substantial changes to the CBAM, taking note of the difficulties encountered in the preliminary phase. The main news concerns a restriction of the scope of application, with the obligation that will apply only to companies that import at least 50 tons per year of one of the regulated assets.
This change foreseen by the Omnibus proposal automatically excludes companies that import smaller volumes, thus limiting the number of subjects obliged to comply with the mechanism.
This decision aims to simplify procedures and reduce administrative burdens for SMEs, which have so far encountered difficulties in adapting to the new reporting obligations.
The measure represents an attempt to Balance regulatory rigor and competitiveness, but its reduced application raises Interrogatives on the effectiveness of the mechanism. If, on the one hand, the aim is to facilitate the adoption of the CBAM, on the other hand, there is a risk of jeopardize transparency and the impact of the measure, leaving a significant proportion of companies exempt from stringent obligations.
What's happening now?
The legislative proposals will now be submitted to European Parliament And to Council for their evaluation and adoption. The changes to the CSRD, CSDDD and CBAM will take effect once the co-legislators have reached a mise on the proposals and after publication in Official Journal of the EU.
In line with the Communication on Simplification and Implementation published onJanuary 11, 2024, the European Commission invites co-legislators to treat the Omnibus package as a priority, in particular with regard to the proposal to postpone certain disclosure obligations provided for by CSRD and the deadline for the transposition of CSDDD, as they aim to respond to key concerns raised by stakeholders.
The draft that amends the regulations currently in force pursuant to Taxonomy will be adopted after the public consultation and will become applicable at the end of the ballot period by the European Parliament and the Council.
