EU Adopts Omnibus I: Sustainability Reporting Rules Recalibrated

· Regulation

On 16 December 2025, the European Parliament adopted the Omnibus I Simplification Package, introducing binding changes to the CSRD and CSDDD that significantly narrow their scope and simplify sustainability reporting and due-diligence obligations. The package raises applicability thresholds, removes sector-specific ESRS mandates, excludes listed SMEs from mandatory CSRD reporting, and limits CSDDD obligations to only the largest EU and non-EU companies. 

On 16 December 2025, the European Parliament formally adopted the Omnibus I Simplification Package, introducing binding amendments to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). The adoption marks a significant recalibration of the EU sustainability regulatory framework, narrowing scope, simplifying obligations, and adjusting reporting and due-diligence requirements for companies.

Omnibus I forms part of the European Commission’s broader legislative simplification agenda and focuses specifically on corporate sustainability reporting and due diligence.


1. Key Changes to the CSRD

  • Revised scope thresholds
    • Mandatory CSRD reporting applies only to:
      • EU companies with more than 1,000 employees and €450 million in net turnover
      • Non-EU companies with net turnover in the EU exceeding €450 million.
      • Branches or subsidiaries of non-EU companies with net turnover in the EU exceeding €200 million.
  • Temporary exemption for certain Wave 1 companies
    • Wave 1 companies that fall below the new thresholds may be exempted from reporting for FY 2025 and FY 2026.
    • This exemption is optional, subject to national transposition, and not automatic.
  • Exclusion of listed SMEs
    • Listed SMEs are removed from mandatory CSRD reporting.
    • They may instead apply the ESRS VSME (Voluntary SME Standard).
  • Sector-specific standards removed
    • The mandate for sector-specific ESRS has been removed.
    • The development of sector-specific guidance remains under consideration.

2. Key Changes to the CSDDD

  • Narrowed scope
    • Due-diligence obligations apply only to companies with:
      • More than 5,000 employees, and
      • Over €1.5 billion in annual net turnover.
    • For non-EU companies, the threshold is €1.5 billion in EU-generated turnover.
  • Removal of climate transition plan requirement
    • The obligation to adopt a climate transition plan under the CSDDD is removed.
    • Under CSRD, companies must still disclose a transition plan if they have one.
  • Removal of EU-wide civil liability regime
    • Harmonised EU civil liability provisions are deleted.
    • Liability will be governed by national law.
    • Administrative fines are capped at 3% of global net turnover.
  • Risk-based due-diligence approach retained
    • Due diligence remains risk-based.
    • Initial assessments focus on identifying the most likely and severe adverse impacts, with deeper investigation required where risks are identified.

3. Next Steps

  • The text now requires formal approval by the Council.
  • The directive will enter into force 20 days after its publication in the Official Journal of the European Union.