What are the most important changes in the omnibus proposal?
| CSRD |
Original directive |
Omnibus |
|
Reduction of scope: Removes ~80% of companies from the CSRD scope
|
>49.000
|
<10.000
|
|
Extension reporting deadlines for 2nd group (large PLCs and limited companies, non-NFRD) and 3rd group (listed SMEs) companies
|
2026 (financial year 2025) for large companies and 2027 (financial year 2026) for listed SMEs
|
2028 (financial year 2027) for large companies (>1000 employees and >50 million euros in revenue or 25 million euros in assets)
|
|
DMA remains cornerstone
|
Double Materiality Analysis
|
Double Materiality Analysis
|
|
Sector-specific reporting standards
|
Expected in 2026
|
No sectoral standards
|
|
Reduction of assurance requirements
|
Starting withlimited assurance, option to move to reasonable assurance after a few years
|
Only limited assurance, further targeted guidance expected
|
| CSDDD |
Original directive |
Omnibus |
|
Limited scope of due diligence:
|
Applied to a wide range of companies, including indirect business partners
|
Focus is on direct business partners. Note: indirect business partners are still within scope when there is an indication of possible abuses
|
|
Reduction of assessment frequency:
|
Required annual ESG impact assessments and effective due diligence activities
|
ESG impact assessments are required every five years instead of annually. Ad hoc still required in case of significant changes in the business situation or new information
|
|
Delay of implementation:
|
Planned compliance date for July 2027 for the first group
|
New compliance date set for July 2028
|
|
Restrictions on information requests in the chain
|
No specific restrictions on the amount and nature of the information that could be requested
|
The amount of information that may be requested as part of the chain analysis by large companies is limited
|
|
Fines and liability
|
Maximum fines of at least 5% of global turnover and companies could be held civilly liable for non-compliance
|
Provisions on fines and civil liability have been removed
|
| EU-Taxonomy |
Original directive |
Omnibus |
|
Simplified EU Taxonomy reporting:
|
Requires detailed reporting on the sustainability of economic activities
|
Introduction of materiality thresholds and an option to report partial alignment (with criteria). Disclosure templates to be simplified and reduced in number
|
|
Simplified DNSH criteria:
|
Includes complex criteria for the ‘Do No Significant Harm’ (DNSH) principle
|
Simplification of the DNSH criter for more practical application
|
|
Reduction of scope
|
Large entities, as per CSRD
|
Large entities, as per CSDDD (more than 1000 employees and more than €450 million turnover)
|
|
Adjustments to the Green Asset Ratio (GAR):
|
Mandatory Green Asset Ratio (GAR) reporting for banks
|
Simplification of the GAR
|
The main changes are summarised above. For a complete and more detailed overview of the proposed changes, please refer to the proposal with Omnibus changes, the EU Omnibus press release, and the EU Commission FAQs.
