EU Omnibus 2025: Current changes to CSRD & CSDDD

Current status of the EU Omnibus

In February 2025, the EU Commission published the so-called Omnibus proposal, which aims to give companies more time to implement their reporting obligations and to reduce the scope of affected companies and reporting requirements. Below you will find the key developments since February 2025.

CSRD / CSDDD

The Stop-the-clock proposal was already adopted in April and postpones the reporting obligations of Wave 2 and 3 companies by 2 years. In June, the Council of the EU also adopted its position on the Commission's substantive Omnibus proposal (#Directive 81), proposing even more far-reaching relief measures. On October 13, the lead JURI Committee of the EU Parliament agreed on a compromise on the Parliament's position, which, however, failed to secure a majority in Parliament on October 22. Parliament now plans to submit a revised proposal by November 13. The trilogue between Parliament, Council, and Commission is then set to begin, ideally leading to a final legislative change by the end of this year.

ESRS

Companies were able to submit feedback on the revised draft of the European Sustainability Reporting Standards (ESRS) until September 29. The final ESRS are expected to be available by the end of November, but will still need to be formally adopted by the EU Commission. Application is planned at the earliest for reports from the 2026 financial year onward.

EU Taxonomy

The substantive adjustments – including the introduction of a 10 percent materiality threshold and the revision of the "Do No Significant Harm" (DNSH) criteria – are under review by Parliament and Council until early January 2026. The planned increase of the application thresholds to companies with more than 1,000 employees and more than €450 million in revenue currently still depends on the outcome of the trilogue mentioned above.

CBAM

The adjustment of the threshold to 50 tonnes per year, importer or material group (excluding electricity and hydrogen), as well as the postponement of the reporting obligations, have officially been in force since October 20.

Timeline of EU Directive 81 and next steps in the Omnibus process

EU Parliament: Revision of the JURI proposal

• On October 13, the JURI Committee of the EU Parliament voted on the Commission's proposal for Directive 81 (Omnibus).
• On October 22, a narrow majority in Parliament rejected the JURI compromise.
• Since then, Parliament has been working on a revised version, expected to be ready by the next session on November 11–13.

Trilogue negotiations between the EU Commission, Parliament, and Council

• The trilogue negotiations on Directive 81 are scheduled for Q4 2025 to Q1 2026.
• The goal is to reach agreement on key points such as CSRD thresholds, the CSDDD liability framework, and the implementation obligations for climate transition plans.

Publication in the Official Journal of the EU

• Following political agreement, publication in the Official Journal of the European Union follows.
• The directive officially enters into force 20 days after publication. This date also marks the start of the deadline for national transposition.

Transposition into national law (planned by the end of 2026)

• Under the Commission's current proposal, member states have a 12-month deadline to transpose the directive into national law.
• At the same time, all parties involved agree that legal certainty should apply across all European states by the end of 2026, which is why great emphasis is placed on concluding the trilogue negotiations by the end of 2025.

Outlook

According to recent reports, the EPP plans to side with far-right parties in the upcoming Omnibus vote on November 13. This would mean:

• Raising the CSRD thresholds to 1,750 employees / €450 million in revenue
• Removal of climate transition plans
• No EU-wide civil liability

It remains to be seen how the situation develops before the vote on November 13.