The EU Omnibus: A Refinement, Not a Retreat

The European Green Deal, passed in 2020, set out to make the EU climate-neutral by 2050, but shifting political and economic realities, including COVID lockdowns, supply chain disruptions, and geopolitical tensions, have reshaped policy priorities. In response, the European Council adopted the Budapest Declaration in November 2024, aiming to enhance economic competitiveness by reducing regulatory burdens, including a 25% cut in reporting requirements by mid-2025. 

As a first step in delivering on this commitment, the European Commission put forward the EU Omnibus in February 2025, a set of proposals designed to simplify and refine corporate sustainability regulations, particularly the Corporate Sustainability Reporting Directive (CSRD), the EU Deforestation Regulation (EUDR), and the Corporate Sustainability Due Diligence Directive (CSDDD). These revisions will ease reporting obligations for some companies while maintaining core sustainability objectives. 

These proposals have a long road ahead before becoming law, but the direction of travel is clear. For those yet to start reporting in line with these frameworks, the EU will likely grant additional time or exempt you from having to report at all. However, for the largest companies who have already published their first CSRD report, the changes are less significant. 

Independent of the unstable regulatory winds, smart leaders recognize that risk often comes with opportunity, and this holds true for nature-related risks as well. Businesses that take a proactive approach to redefining their relationship with nature are not only strengthening their own resilience but also contributing to a more stable operating environment for all. Integrating nature and its associated risks into strategic planning is crucial for long-term value creation. Voluntary frameworks that move beyond CSRD, such as the Taskforce for Nature-Related Financial Disclosures (TNFD), provide practical guidance on how to make it a core part of your approach.

What’s Changing and How Should Businesses Adapt?

In our recent webinar, we covered the EU omnibus and its implications for corporate sustainability and several key takeaways emerged that businesses should be aware of:

CSRD: Refining Scope and Reducing Compliance Burden

The Corporate Sustainability Reporting Directive (CSRD) was initially designed to expand corporate accountability by requiring companies to report on environmental and social impacts, including biodiversity, water, and pollution risks.

The Omnibus refines CSRD’s application, primarily by:

  • Raising Reporting Thresholds – The employee threshold has increased from 250+ to 1,000+ employees, reducing the number of in-scope companies by over 80% (from 50,000+ to <7,000).
  • Focusing on Larger Enterprises – Non-EU companies are now only covered if their EU turnover is above €450m (previously €150m).
  • Removing Sector-Specific ESG Standards – Industry-specific sustainability reporting requirements have been eliminated, removing tailored guidance for high-impact sectors such as mining, forestry, and agriculture.
  • Providing a Two-Year Reporting Extension – Many businesses now have additional time before compliance is required.
  • Streamlining Data Requirements – Reducing required data points aims to simplify sustainability reporting, focusing on quantitative data points.
  • Limiting Value Chain Reporting Requirements – Large companies (>1,000 employees) are now restricted in how much data they can request from smaller suppliers, addressing concerns about administrative burdens.

Impact: While CSRD still applies to large enterprises and financial institutions, the exemption of SMEs and removal of sector-specific guidance may reduce granularity in nature-related disclosures. This could create challenges for investors assessing biodiversity and climate-related financial risks.

Key Takeaway: While reporting burdens are reduced for smaller companies, businesses committed to sustainability leadership should continue voluntary disclosures to maintain transparency and stakeholder trust.

CSDDD: A More Targeted Approach to Due Diligence

The Corporate Sustainability Due Diligence Directive (CSDDD) was designed to ensure that companies assess and mitigate environmental and human rights risks across their supply chains. However, the Omnibus introduces a more focused approach:

  • Due Diligence Now Applies Only to Direct Suppliers – Previously, firms had to assess risks across their entire supply chains, but now obligations are limited to first-tier suppliers.
  • Lower Compliance Burden for Businesses – While this change reduces complexity, it also means that indirect suppliers (where many environmental risks originate) may no longer be scrutinized.
  • Less Frequent Risk Assessments – Companies are now required to review supply chain risks every five years instead of annually.

Impact: CSDDD still plays a crucial role in supply chain sustainability, but businesses in high-risk industries (such as agriculture, fashion, and electronics) may need to conduct voluntary due diligence beyond direct suppliers.

Key Takeaway: If your supply chain has indirect exposure to deforestation, pollution, or biodiversity risks, relying only on CSDDD-compliant due diligence may be insufficient to meet investor expectations.

Political & Industry Implications

The EU Omnibus is still a proposal and will go through multiple rounds of discussions in Parliament, the Council, and the Commission before becoming law. The political landscape is evolving, with the position of key member states having shifted markedly against sustainability reporting in recent months.

Germany has positioned itself as a leader in pushing for deregulation, advocating for reduced administrative burdens on companies. Italy and Spain have expressed concerns about losing competitive advantage due to uneven reporting requirements, fearing that companies in their jurisdictions may be at a disadvantage compared to those in less regulated markets. France, once a strong advocate for sustainability reporting, has notably shifted from a pro-sustainability stance to favoring deregulation, aligning more with business interests.

On the industry side, financial institutions are increasingly worried about how the Omnibus will affect SFDR (Sustainable Finance Disclosure Regulation). Without standardized reporting, the ability to assess sustainability-related financial risks may be compromised. Furthermore, the European Central Bank (ECB) continues to require banks to assess climate and biodiversity risks, emphasizing the ongoing importance of sustainability considerations even as regulatory obligations shift.

The Bigger Picture: A Shift in How Sustainability Regulations Align

Rather than fully integrating sustainability regulations, the EU Omnibus shifts the focus toward larger enterprises and direct supply chain oversight, while reducing reporting burdens for SMEs and eliminating sector-specific standards. This leads to:

  • Less transparency in nature-related disclosures, making it harder for financial institutions to assess biodiversity and pollution risks.
  • A narrower focus for CSDDD, limiting the scope of corporate due diligence to direct suppliers rather than entire supply chains.
  • A disconnect between CSRD, CSDDD and EUDR compliance, as businesses may struggle to demonstrate deforestation-free supply chains without structured sustainability reporting.

The result? Businesses must navigate a more fragmented sustainability landscape where reporting and compliance obligations do not always align.

What Should Businesses Do?

Despite regulatory shifts, investor expectations remain high and risks to business are becoming ever more material. Businesses should take a proactive approach to managing nature-related risks:

Maintain Voluntary Sustainability Reporting

Even with fewer mandatory disclosures under CSRD, companies with material nature-related risks are encouraged to align with voluntary frameworks such as TNFD (Taskforce on Nature-related Financial Disclosures). This enables companies to capture business value by properly measuring and managing material nature-related risks.

Strengthen Supply Chain Oversight

While CSDDD no longer requires deep supply chain due diligence, businesses operating in high-risk sectors should implement independent supply chain risk assessments to maintain credibility.

For more detailed guidance, download the webinar replay here

Next Steps & Open Questions

The Omnibus still requires final negotiations in Parliament & Council, which will determine the ultimate regulatory framework. While the simplification of reporting requirements is a significant change, businesses should prepare for ongoing stakeholder pressure from investors and regulators like the ECB, ensuring sustainability remains a strategic priority.

Several key uncertainties remain, including:

  • Will reporting delays be one year or two years? The final decision will impact compliance timelines and strategic planning for businesses.
  • Will CSRD requirements for SMEs be reconsidered? Changes in reporting obligations could affect the breadth of corporate sustainability disclosures.
  • How will the value chain cap be interpreted and enforced? Businesses need clarity on data collection limitations from smaller suppliers and how enforcement mechanisms will be applied.

Final Thoughts: A Refinement, Not a Retreat

The goal of the CSRD remains the same, improving transparency on sustainability topics, which means disclosure requirements are still likely to align with best practices such as those promoted by TNFD. However, with updates to the ESRS standards not expected before 2026, significant uncertainty remains around the specifics of future reporting obligations. Despite these delays, sustainability risks and investor expectations are not disappearing, and companies should continue integrating sustainability into strategic decision-making rather than treating it as a compliance burden.

What’s next? Businesses will have to balance regulatory compliance with investor and stakeholder expectations. While reporting obligations may shrink, market scrutiny of sustainability will not.

Unsure how your organisation is navigating these regulatory changes?

Let’s discuss.

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