As a result, there has been an increase in the proposed Corporate Sustainability Reporting Directive (CSRD) employee threshold from 1,000 to 1,750 full-time equivalent employees. In addition, the EP proposed to remove transition plan requirements for climate change from the Corporate Sustainability Due Diligence Directive (CSDDD).
Background
Since 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 CSDDD requirements and has undergone several rounds of negotiation within the EU legislative process to date.
On 13 October 2025, the EP Legal Affairs (JURI) Committee approved its position on the proposed changes to the Omnibus package. However, this initial position was subsequently narrowly defeated in a vote at the plenary session on 22 October 2025.
On 13 November 2025, a revised position was proposed and approved at the current plenary session. This version contains certain changes from the 13 October position that will further reduce the scope of reporting compared to the previous position as described in the next section. The press release is available here.
While the EP has approved its position, there are still steps that need to be taken for these changes to be finalised, including negotiations on the final text with the EU governments.
Summary of revised 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
| 13 October position | 13 November position | |
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Reduction in scope
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This position proposes thresholds of 1,000 full-time equivalent (FTE) 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 initial thresholds. The position also proposes an EU net turnover threshold for non-EU entities of €450 million, with no associated employee threshold.
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This position proposes an increased threshold of 1,750 FTE employees. The other reduction in scope items are otherwise unchanged from the October position.
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Information request limitation
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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.
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No change from the October position
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Digital portal
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The European Commission has agreed to establish a digital portal containing free templates, guidelines and information
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No change from the October position
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CSDDD changes
| 13 October position | 13 November position | |
|---|---|---|
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Reduction in scope
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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.
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No change from the October position
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Risk-based approach
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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.
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No change from the October position
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No EU wide liability
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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.
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No change from the October position
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Transition plan
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Not addressed in this position
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The revised position removes the previous requirement to put into effect a transition plan for climate change mitigation to be compatible with the Paris Agreement.
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Next steps
With this vote complete, the process now moves to negotiations between the EP and European Council as legislators, with the European Commission facilitating this negotiation. The Trilogue discussions are expected to begin this week, with the ambition to have the negotiations completed by 8 December and final legislation by the end of 2025. Given there are still differences in the proposals from all three institutions, it remains to be seen what the final legislative proposal will look like once the compromises are agreed upon and negotiations have concluded. The differing positions also create uncertainty regarding whether the legislation can be finalised this year.
Our thoughts
Whatever is on the horizon for reduced mandatory European sustainability reporting obligations, we still maintain that this should not automatically result in a lower ambition for sustainability reporting. We have observed that companies that embed sustainability in their strategy ensure that the use of time and resources results in value creation for the entity, its stakeholders and society as a whole.
We have published several other alerts related to the Omnibus package. For more information, click here:
- The Omnibus package – European Commission releases significant proposals to simplify EU
- Omnibus package stop-the-clock proposal adopted by European Parliament
- The European Commission adopts a new Delegated Act to Simplify EU Taxonomy reporting requirements
- European Commission adopts ‘quick fix’ amendments to ESRS for Wave 1 entities
- EFRAG releases revised ESRS Exposure Drafts
- EU Parliament continues negotiations on reduced sustainability reporting and diligence requirements