Sustainability Reporting in the EU
CSRD Under the Omnibus Package: What’s Changing and When?
Philipp Petry
Chief Sustainability Officer
On February 26, 2025, the European Commission introduced a proposal for the first “Omnibus” Package on sustainability regulation and reporting. This proposed legislation covers multiple areas, but we have taken a closer look at the Corporate Sustainability Reporting Directive (CSRD) - one of the most impactful regulations shaping corporate ESG disclosures.
Key Changes in the CSRD
The Omnibus Package significantly reduces the CSRD scope, cutting reporting obligations for around 80% of companies while refining the reporting framework. Here are the major updates:
- Higher thresholds: Only companies with more than 1,000 employees and either €50M turnover or €25M in total assets will be required to report.
- SMEs relief: Listed SMEs are fully exempt from mandatory reporting.
- Delayed phase-ins: The timeline for certain companies has been pushed back to 2028/2029 instead of 2026/2027.
- Less complexity: Fewer data points, no sector-specific standards, and simplified materiality assessments.
- Limited assurance remains: No shift to "reasonable assurance", reducing compliance costs.
Who Still Needs to Report? New vs. Old CSRD Thresholds
Here’s a quick comparison of the new CSRD thresholds vs. the previous requirements:
When Will the New CSRD Rules Apply?
The Omnibus Package is expected to take effect in 2025, but several steps need to happen first:
- The EU Commission must finalize the revised CSRD framework.
- EFRAG has six months to revise the European Sustainability Reporting Standards (ESRS).
- The EU Parliament & Council must approve the changes.
- Companies will apply the revised ESRS in late 2025/early 2026.
- Further updates will have a 24–36 month transition period to ensure stability.
This means businesses can expect clarity on the final reporting requirements by early 2026, with updated reports first due in 2027 (for FY 2026).
What Does This Mean for ESG Professionals?
- Legal certainty for large companies, allowing them to proceed with CSRD implementation with confidence.
- ESG data remains essential—even companies not subject to mandatory reporting should be prepared for data requests from banks and investors.
- The VSME standard provides an alternative for voluntary reporters who fall outside the mandatory scope.
Summary: What’s Changing for Businesses?
The CSRD changes primarily impact the scope of companies required to report and the reporting obligations themselves. Companies in the second wave of CSRD implementation now get a two-year delay due to the "Stop-the-clock" measure.
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