Mar 3, 2025
What is the Omnibus Proposal?
The Omnibus proposal, officially presented on February 26, 2025, introduces substantial and far-reaching modifications to the existing Corporate Sustainability Reporting Directive (CSRD) framework. This comprehensive proposal, while currently still navigating the formal adoption process and subject to potential revisions, represents potentially transformative changes to the sustainability reporting landscape across the European Union.
If implemented as proposed, it would fundamentally reshape compliance requirements and reporting obligations for thousands of companies operating within EU jurisdiction.
With that in mind, we at SustainLab want to make it clear that we can support companies and organisations with the uncertainty this poses irregardless of where a company is in their CSRD journey. Here, we have outlined the major key changes that the Omnibus proposal might bring if it is passed.
Brief overview of the key changes:
Reporting Scope: Previously, companies had to meet two out of three criteria: 250+ employees, €50M turnover, or €25M balance sheet. Now, companies must have 1000+ employees AND either €50M turnover or €25M balance sheet.
Full Reporting Threshold: Previously, all in-scope companies needed to comply with full CSRD reporting including the EU taxonomy. Under the proposal, only companies with 1000+ employees AND €450M turnover will be required to report fully with the taxonomy.
Implementation Timeline: Originally, large companies (500+ employees) were to start in 2025, other large companies in 2026, and listed SMEs in 2027. The "Stop the clock" provision postpones CSRD implementation for listed SMEs (wave 2 and 3) by two years; CS3D is delayed until 2028.
Reporting Standards: Previously, companies had to follow full ESRS, including sector-specific standards. The proposal eliminates sector-specific standards and introduces a simplified ESRS for voluntary reporting, while limited assurance requirements remain.
Supply Chain Protection: Previously, large companies could request extensive sustainability data from smaller suppliers. The new "Value-chain cap" means smaller companies cannot be required to provide more information than what is included in the voluntary standard.
ESRS Development: Previously, a single ESRS framework applied to all in-scope companies. Under the proposal, a new simplified ESRS for voluntary reporting will be developed.
Current status
The Omnibus is currently only a proposal with ongoing intensive work on details and timelines. Adoption is requested on a fast-track, but we do not know today what the implementation timeline is. Thus, we advise all companies to ensure a consequential dialogue with your auditors and legal team as you decide on your path forward.At the moment, the proposal is at a draft stage, and there will be discussions before any adoption, and it has to pass through the European Parliament and the Council, and subsequently through EU Member States national laws before it is formalised.
Our recommendations
With these proposed changes, we want to clarify how we'll continue supporting your sustainability data needs. Here's how we can help based on your situation:
If you're still required to report under CSRD: We'll support your reporting journey every step of the way. Focus on building good data systems and celebrate what you've already accomplished!
If your reporting requirements might change - stay on the path for now, and ensure that you minimise risks for non-compliance.
We can help you either continue with full ESRS reporting or switch to the simpler VSME standard. Build on what you've already done and focus on the most important areas from your DMA.If you're no longer required to report: There's still value in good sustainability practices. The new simplified standard VSME may become the norm, and we can help you align with it. We see that sustainability and sustainability reporting are become quintessential, and thus, we want to support you on that journey equally as companies doing it for compliance reasons.
Building systems that last
No matter what happens with regulations, our approach helps future-proof your sustainability work by:
Collecting detailed data from the ground up that can be used for multiple purposes, and that gives you the advantage of a data driven and knowledge driven sustainability work
Creating flexible strategies that can adapt to changing rules, i.e., having processes in place that make sure that you do not build yourself into a black box
Focusing on quality information that adds real value, what data can drive change within your organisation?
Even as regulations change, sustainability remains essential for business. We're here to help you navigate these changes while making sure your sustainability efforts continue to benefit your organization.
Read more about our voluntary CSRD reporting solution for SME:s here
