Since the Corporate Sustainability Reporting Directive (CSRD) initially came into force in the European Union (EU) on 1 January 2023, there have been increasing demands to streamline the requirements and reduce the reporting burden associated with sustainability reporting.
The Omnibus package, initially released in February 2025, is intended to meet this demand for simplification. It contains proposed changes to the CSRD and Corporate Sustainability Due Diligence Directive (CSDDD) requirements and has undergone several rounds of negotiation within the European Union (EU) legislative process to date.
On 13 October 2025, the EU Parliament (EP) Legal Affairs (JURI) Committee took another step towards finalising the Omnibus and approved its position on the changes proposed. While the EU Parliament has reached an agreement, there are still steps that need to be taken for this position to be finalised. The EP will vote on the position at the plenary session currently planned for 20 October 2025, followed by negotiations on the final text with the Members of the European Parliament (MEPs) and EU governments from 24 October 2025.
Summary of position
The EP position contains proposed changes to both the CSRD and CSDDD that are intended to reduce reporting burden, and are detailed below:
CSRD changes
- Reduction in scope: This position proposes thresholds of 1,000 employees and net turnover of €450 million for EU entities to be in scope for CSRD reporting, which will reduce the number of entities that will be required to report compared to current thresholds. The position also proposes an EU net turnover threshold for non-EU entities of €450 million, with no associated employee threshold.
- Information request limitation: The position includes a limitation on the information that larger entities can request from their value chain partners that are out of scope of the CSRD. Reporting entities that are in scope of the CSRD will be prevented from requesting information beyond what is required by voluntary standards from out-of-scope entities in their value chain.
- Digital portal: The EC has agreed to establish a digital portal containing free templates, guidelines, and information.
CSDDD changes
- Reduction in scope: The position proposes CSDDD thresholds of 5,000 or more employees and over €1.5 billion in revenue, which will drastically reduce the number of entities in scope compared to current thresholds.
- Risk-based approach: The position introduces a risk-based approach, whereby entities are only required to ask for necessary information if there is a reasonable expectation of an adverse impact on their business partners’ activities, rather than systematically asking for the required information.
- No EU wide liability: The position indicates that obligations arising as a result of breaches of the CSDDD will be covered under national law, rather than at the EU level.
Our thoughts
We are pleased to see that the simplification efforts are a top priority for the EP and the EC. In particular, the cap on the information that in-scope entities can request from value chain partners will hopefully prevent larger reporting entities from shifting the reporting burden to smaller entities.
However, we believe the simplification process has been complicated and time-consuming, and has still not been finalised. The uncertainty surrounding what the changes will be and when they will be approved has introduced confusion surrounding the process, which we hope to see resolved soon with a clear set of final requirements being available.
We have published several other alerts related to the Omnibus package. For more information, click here:
