What is the EU Omnibus?

On February 26, 2025, the European Commission published an "Omnibus Simplification Package."

This proposal aims to streamline reporting obligations under key EU sustainability directives:

• Corporate Sustainability Reporting Directive CSRD
• Corporate Sustainability Due Diligence Directive CSDDD
• EU Taxonomy
• Carbon Border Adjustment Mechanism - CBAM

It is very important to note that there are no changes at this time, while the proposals are under review.

The proposal covers suggestions for reducing “who” should report and “what” should be reported. The suggestion is an attempt to lessen the regulatory burden on EU companies, both resource wise and investment wise.

The European commission suggests that this could save €6.3 billion in annual administrative costs and unlock €50 billion in public and private investments for policy priorities.

The Commission states that there have been many concerns of stakeholders, who consider that some sustainability reporting and due diligence rules are too complex and costly to implement, and of limited usefulness for investors and others, hindering the EU's competitiveness and its investment drive.

The proposals will now be submitted to the European Parliament and the Council for their consideration and adoption.

How does Omnibus impact CSRD

The proposal aims to narrow the scope of companies required to report. Under the current framework, companies with more than 250 employees and €40 million in revenue were obligated to report, covering approximately 50,000 companies across the EU and 2,000 in Denmark over time.

Listed companies that fall below the new limits are thus also exempt from the reporting requirements.

The revised proposal raises the threshold to 1,000 employees and €50 million in revenue, reducing the number of reporting companies by around 80%. In Denmark, this would mean a shift from almost 2,000 companies to just 100.

Additionally, the requirement for reasonable assurance has been removed, and companies that have not yet reported will receive a two-year extension on their reporting deadlines.

Impact	CSRD today	New Proposal
Scope	Companies with 250 employees and 4 m EUR in revenue. Approx. 50.000 companies in EU, approx. 2.000 companies in DK	Companies with 1.000 employees and 50 m EUR in revenue=80% less companies. Approx. 7.000 companies in EU, approx. 100 companies in DK
Timeframe	First wave: 2025 2nd wave: 2026 3rd wave: 2027	Prolonging it with 2 years, for companies (2nd and 3rd wave) that have not reported yet)
ESRS	12 standards with 1.000+ data points	Reduction of data points
Sector Specific	Mandatory sector specific standards to be introduced in 2026 for Oil and Gas, Mining, Quarrying and Coal Mining, Road Transport, Textiles, Accessories, Footwear, and Jewelry, Financial Institutions, Agriculture, Farming and Fishing, Motor Vehicles, Energy Production and Utilities, as well as Food and Beverages	Completely removed
DMA	Mandatory	The principle will be maintained
Reporting	Limited assurance necessary, plans to require Reasonable Assurance	Limited Assurance still necessary, but Reasonable Assurance will be removed.
Value Chain	Collect data from all suppliers	Not required to collect data form non-CSRD companies. VSME standard will be used

How does Omnibus impact CSDDD

Until 2029, only companies with over 5,000 employees and €1.5 billion in revenue were required to report. After 2029, this threshold was set to expand to companies with 1,000 employees and €450 million in revenue. The revised proposal increases the threshold to 1,000 employees and €450 million in revenue, to streamline it with CSRD.

The new proposal suggests extending the implementation deadline by one year, allowing companies to delay compliance from July 2027 to July 2028. Additionally, the reporting scope has been reduced, shifting the requirement from covering the entire value chain to only Tier 1 suppliers.

Companies must also address other parts of the supply chain if there are plausible indications of human rights or environmental violations. Negative impacts further down the supply chain must be mitigated through "contractual cascading", requiring Tier 1 suppliers to comply with the company's code of conduct and enforce the same standards within their own supply chains.

Additionally, the right to request information is restricted for companies with fewer than 500 employees, but such requests are still allowed if deemed necessary and proportionate.

Impact	CSDDD today	New Proposal
Scope	All suppliers in the value chain	Only Tier 1 suppliers
Timeframe	Implementation in July 2027	Implementation in July 2028
Assessment	Yearly assessment of suppliers	Every 5th year
Liability	Civil liability could be claimed for non compliance	Removed
Transition plans	Mandatory to implement transition plans	Have to adopt transition plans but not implement them
Downstream due diligence	Requirement for financial institutions was considered	Removed
Sanctions	Min. 5% of global revenue	Removed
Requirements	Member states could impose stricter requirements on certain areas	Reducing regulatory flexibility on possibility to adopt stricter national due diligence requirements in key areas like risk assessment, value chain due diligence, and sanctions

What does Omnibus say about EU Taxonomy

The EU Taxonomy reporting requirement is proposed to only apply to CSRD-covered companies with revenue over €450 million. Companies below this threshold can voluntarily report under simplified standards.

Key changes include:

• Simplified reporting templates
• OpEx reporting made voluntary
• Materiality threshold set at 10% of revenue, CapEx, or total assets
• Reduced complexity in the "Do No Significant Harm" (DNSH) criteria

How does Omnibus impact CBAM

The CBAM is the EU’s tool to ensure a fair carbon price on imported carbon-intensive goods and to promote cleaner industrial production outside the EU. By confirming that imported goods pay the same carbon price as EU-produced goods, CBAM prevents carbon leakage and ensures that the EU’s climate objectives remain intact. It is WTO-compliant and designed to align with international trade rules.

The changes will exempt small importers from CBAM obligations, mostly SMEs and individuals. These are importers who import small quantities of CBAM goods, representing very small quantities of embedded emissions entering the EU from third countries. Importers handling less than 50 tonnes of CBAM goods annually(approximately 80 tonnes of CO₂ equivalent) will be exempt from CBAM obligations. This exemption spares 90% of importers from reporting while still covering 99% of emissions entering the EU.

Streamlined Compliance for Larger Importers: For importers that remain within CBAM’s scope, the proposal simplifies emissions calculation, reporting requirements, and declarant authorization. It also introduces stronger anti-abuse measures and a joint anti-circumvention strategy in collaboration with national authorities.

Next steps and future expansion: A full CBAM review is planned later this year to assess its potential extension to other ETS sectors, downstream goods, and indirect emissions. Additionally, the Commission will evaluate support measures for exporters at risk of carbon leakage, with a legislative proposal expected in early 2026.