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The seven strategic priorities of the 2025 Work Programme:
• Sustainable prosperity and competitiveness
• Defence and security
• Support for citizens and the European social model
• Quality of life and the environment
• Safeguarding democracy and EU values
• Europe in the world
• The future of the EU and enlargement
Environmental objectives in the 2025 Programme
• Sustainable prosperity and competitiveness: The Clean Industry Pact aims to cut emissions by 90% by 2040 while fostering economic growth.
• Quality of life and environment: The vision for agriculture and food supports farmers with a more stable framework. The Ocean Pact creates a unified system for protecting marine ecosystems and promoting the blue economy. The European Water Resilience Strategy introduces measures for sustainable water use and climate adaptation.
What is the Omnibus package and why does it matter?
As part of the 2025 Work Programme, the European Commission introduced the Omnibus Simplification Package - a set of legislative revisions designed to reduce bureaucracy and simplify ESG compliance for companies. These changes impact the CSRD (Corporate Sustainability Reporting Directive), the CSDDD (Corporate Sustainability Due Diligence Directive), and the EU Taxonomy.
Key changes introduced by the Omnibus Package
• Reduced scope of companies impacted – Thresholds for applicability have been raised, excluding some SMEs from mandatory ESG reporting.
• Extended reporting timelines – Companies now have more time to prepare for ESG reporting obligations.
• Simplified reporting requirements – Certain complex or burdensome obligations have been removed.
• Clearer guidance on due diligence – The CSDDD now provides more practical instructions for managing ESG risks across supply chains.
• More flexibility in the EU Taxonomy – Definitions of sustainable activities are being adapted to better reflect the realities of certain industries.
How do these changes affect companies?
CSRD: What has changed?
Applicability thresholds have been revised, reducing the number of companies required to report under the ESRS.
Previous thresholds: Companies were subject to CSRD if they met two of the following three criteria:
• Net turnover of at least EUR 50 million
• Total assets of at least EUR 25 million
• At least 250 employees
Updated thresholds: Under the Omnibus Package, only companies that meet the following criteria will be required to report:
• Over 1,000 employees and
• Either a net turnover of at least EUR 50 million or total assets of at least EUR 25 million
This change is expected to exclude approximately 80% of companies that were previously within scope, focusing mandatory reporting on the largest entities.
Reporting timelines have been extended.
Original timeline
• Wave 1: Public interest entities with over 500 employees – starting FY 2024
• Wave 2: Other large companies – starting FY 2025
• Wave 3: Listed SMEs – starting FY 2026
Updated timeline:
• Wave 2: Reporting begins FY 2027
• Wave 3: Reporting begins FY 2028
Certain disclosures, such as supply chain data, are no longer mandatory for all companies.
CSDDD: What’s new?
1. Postponed compliance deadline
• Previous deadline: Large companies had to comply with the CSDDD by July 26, 2027
• Updated deadline: The Omnibus Package extends this deadline to July 26, 2028
2. Narrower due diligence obligations
• Before: Companies were required to assess the entire value chain, including indirect partners
• Now: Due diligence obligations are limited to direct business partners (Tier 1). Assessments of indirect partners are only necessary when significant risks are identified
3. Lower frequency of due diligence assessments
• Before: Companies had to perform due diligence annually
• Now: Assessments are required once every five years, reducing administrative workload
4. Changes to the sanctions regime
• Before: Companies could face fixed penalties up to 5% of global turnover
• Now: A proportional sanctions system is introduced, adjusted to the severity and nature of the violation, offering a fairer approach
5. More flexibility in business relationships
• Before: Companies were required to terminate relationships with non-compliant partners
• Now: Companies have the option to temporarily suspend relationships or apply corrective actions, instead of terminating contracts outright
EU Taxonomy: What has been updated?
1. Clarification of sustainable activity definitions
The Omnibus Package includes additional guidance on applying technical screening criteria and respecting the “Do No Significant Harm” (DNSH) principle. These clarifications help companies better understand how to classify their activities as sustainable and promote consistent application of the taxonomy.
2. Simplified reporting requirements
To reduce administrative burdens, the European Commission has published FAQs to support implementation. These provide practical instructions on applying the technical criteria and DNSH principle during ESG reporting.
Most frequently asked questions about the Omnibus package
Does my company need to report ESG under the CSRD?
It depends on the new applicability thresholds. Consult an ESG expert to assess your obligations.
When do we need to start ESG reporting under the CSRD?
Although deadlines have been extended, early preparation is key. Start now to avoid future delays.
How does the CSDDD affect our supply chain?
You’ll need a clearer due diligence process, but requirements have been eased for certain sectors.
Will the EU Taxonomy changes impact my business?
If your activity was previously considered non-sustainable, the new flexibility may now allow for reclassification.
What should we do next?
- Check if your company falls under the new CSRD thresholds
- Speak with an ESG specialist to assess your exposure
- Begin building an action plan to ensure compliance with the updated requirements
Conclusion: Real simplification or just a delay?
The Omnibus Package provides more flexibility, but also increases the urgency to adapt. In an uncertain regulatory landscape, companies cannot afford to pause their CSRD readiness efforts. Delays may ease pressure temporarily, but the best strategy is to keep moving forward - conduct a Double Materiality Assessment, perform a gap analysis, and align your sustainability roadmap with both current and upcoming expectations. Maintaining active communication with senior leadership and decision-makers will be essential to navigate the evolving EU regulatory framework effectively.