What you need to know about the EU Omnibus proposal

The European Commission introduced the "Simplification Omnibus" package, proposing amendments - that are not yet enforced - to the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Taxonomy.

These proposals, pending legislative approval, aim to reduce the complexity and breadth of non-financial reporting for businesses operating in the EU. This proposal has created a lot of noise, which might be hard to cut through.

Plan A helps you stay updated on any regulations, with this article on the latest developments, and anticipate what is ahead.

1. Context and rationale behind the proposed amendments

The CSRD was established to enhance corporate transparency regarding environmental, social, and governance (ESG), enabling stakeholders to make informed decisions on their suppliers and business partners. The Directive is not designed to report for the sake of reporting but to push companies to create visibility on previously ignored dependencies. This would, in turn, allow companies to weather predictable and upcoming stresses such as:

• Unpredictable supply chains: Climate events, geopolitical tensions, and global health crises have disrupted supply chains, necessitating greater visibility and resilience in operations.
  
  
• Rising energy costs: Fluctuations in energy prices have increased operational expenses, prompting companies to seek energy-efficient solutions and alternative energy sources. Reducing energy needs is primordial.
  
  
• Need for autonomy and independence: Businesses must reduce their dependencies to maintain their operations, and local sourcing has become a company asset.

The EU non-financial world is a complex set of procedures. The European Commission's proposed amendments aim to reduce administrative burdens and extend the time allocated to businesses to prepare for reporting on these data points.

Regardless of its final form, Plan A’s CSRD Manager breaks down the complexity of CSRD and prepares your company for in-depth non-financial reporting (and performance).

2. Key proposed changes 

The proposed amendments propose several significant modifications. Keep in mind these changes are proposals, not laws:

• Threshold adjustments: The employee threshold for mandatory CSRD compliance is proposed to increase from 250 to 1,000 employees. This change would exempt many small and medium-sized enterprises (SMEs). Companies approaching this threshold can voluntarily utilise the extended timeline to enhance their sustainability practices, positioning themselves for future, inevitable non-financial regulations.
  
  
• Reporting scope reduction: The focus of the Corporate Sustainability Due Diligence Directive (CSDDD) is proposed to shift primarily to direct suppliers, with mandatory assessments occurring every five years instead of annually. Businesses can use this extended interval to build stronger relationships with key suppliers, implement robust monitoring systems, and focus on the most impactful suppliers.
  
  
• Implementation timeline extensions: The enforcement of specific CSRD provisions are proposed to be deferred to 2028 for companies in the second and third reporting wave, with the application of the CSDDD potentially postponed to mid-2028. This extension provides companies additional time to align their operations with new requirements. Leverage this period to integrate sustainability into your company’s core strategies and automate the reporting.

3. What is not changing about the CSRD?

Understanding what is not changing about CSRD is essential for companies as they prepare for compliance. Some countries have transposed the CSRD into national laws; others are still in the draft stage. Those laws will continue to be enforced throughout the discussions. 

Here are the main elements that are not changing:

1. Scope of reporting: The CSRD will require companies to report on various sustainability issues, including environmental, social, and governance (ESG) factors. This comprehensive approach ensures that companies address their impacts on multiple stakeholders and the environment.
   
   
2. Materiality assessment: The requirement for companies to conduct a materiality assessment to identify relevant sustainability topics remains unchanged. Companies must assess which sustainability issues are most significant to their operations and stakeholders, ensuring that their reports focus on material aspects.
   
   
3. Integration with financial reporting: The CSRD continues to emphasise the integration of sustainability reporting with financial reporting. Companies are expected to provide a holistic view of their performance, linking sustainability impacts to economic outcomes, which is essential for understanding long-term value creation. It is key for businesses to take advantage of the time to continue building systems capable of ingesting financial data and combining financial with non-financial reporting.
   
   
4. Stakeholder engagement: The importance of engaging with stakeholders to gather insights and feedback on sustainability practices remains a core principle of the CSRD. Companies should consider stakeholder perspectives when developing and reporting their sustainability strategies.
   

The final CSRD regulations will take multiple forms because the Directive is being transposed in different legislatures. This means that each country has its own slightly changing CSRD regulations. Tools like the Plan A CSRD Manager support the reporting officer in collecting all the required data and compiling the report, but, more importantly, they create a repeatable motion to streamline complex reporting and are capable of considering changes in reporting scopes.

4. Immediate actions for business leaders

In light of the proposed amendments, the following immediate actions are advisable:

• Inform stakeholders: Communicate and clarify that this proposal has not been voted into law and explain what does not change.
  
  
• Continue preparedness initiatives: Despite the proposed relaxations, persisting with existing compliance preparation is prudent. The CSRD has already been transposed into national law in several countries, including Belgium, Bulgaria, Croatia, Denmark, Finland, France, Greece, Hungary, Ireland, Italy, Norway, Poland, and Romania. These laws remain enforceable until any new amendments are officially adopted and implemented, a process that could extend over a year or more.
  
  
• Focus on enduring reporting requirements: Concentrate efforts on aspects of sustainability reporting that are unlikely to change, such as carbon accounting and double materiality assessments. These elements are foundational to sustainability reporting and will continue to be critical in demonstrating corporate responsibility. Create your first reports in 2025 or 2026 to ensure the team is familiar with standards and reporting formats.

5. Longer-term considerations

Pausing sustainability reporting efforts and anticipating regulatory changes could be the most detrimental action. Companies leveraging sustainability can lower costs and insulate from partners’ failures to prepare and generate better business models.

One thing is clear: transparency and accountability will remain non-negotiable regardless of how the Omnibus Proposal evolves. While the EU is moving to simplify regulations, the broader shift toward sustainability, decarbonisation, and responsible business practices is here to stay.
- Nathan Bonnisseau, Co-founder, Plan A.

Businesses can expect that continuing preparedness to merge financial and non-financial indicators will still be a must:

Sustained commitment to sustainability: Maintaining comprehensive sustainability practices ensures compliance, enhances corporate reputation, fosters investor confidence, and contributes to long-term value creation. Companies that integrate sustainability into their core operations are better positioned to navigate future challenges and capitalise on emerging opportunities.

Adaptive compliance infrastructure: Invest in scalable and adaptable reporting systems capable of accommodating current requirements and future changes to the regulations. Over time, it is doubtful that non-financial reporting will disappear because it has been established that we need to create visibility on liabilities such as biodiversity loss, water usage, and heightened natural disaster risks, amongst many others. Companies can also reduce costs and optimise their business models and operations using non-financial approaches. 

We strive to provide the visibility companies need on these complex topics. We will continue to monitor and communicate on our channels about the legislative process around CSRD, CSDDD and the EU Taxonomy Regulation.  

Companies that proactively adapt, not just to compliance requirements but to stakeholder expectations, will be best positioned for long-term success. In an ever-changing regulatory landscape, demonstrating clear, credible climate action will remain a key differentiator.

Stay ahead of regulatory changes with ease. Book a demo with Plan A and streamline your sustainability reporting today