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Sustainability update

December 2025

Highlights

  • EFRAG provides technical advice with draft Amended ESRS to Commission
  • ENVI-ECON Committees reject motion for resolution to object EU Taxonomy ‘Omnibus’ DA
  • European Parliament supports further delay and simplifications of Deforestation-Free Products Regulation
  • Ombudswoman finds Omnibus I a case of maladministration
  • European Commission simplifies rules for sustainable financial products
  • IAASB provides examples on how to apply ISSA 5000

Feature story

EU co-legislators reach provisional agreement on Omnibus proposal

On 8 December, the European Parliament (EP) and the Council stroke a deal on the Omnibus proposal amending sustainability reporting and due diligence rules.

Below we share a summary of key elements in the provisional agreement

Corporate Sustainability Reporting Directive (CSRD):

  • applies to undertakings with more than 1,000 employees and exceeding a net turnover of €450 million; a further assessment of scope extension is planned for 2031
  • exemptions from consolidated reporting applies to financial holding undertakings; exemption applies to subsidiaries which are public-interest entities if its parent undertaking reports on consolidated basis
  • Member States may exempt undertakings which do not exceed 1000 employees and EUR 450 million net turnover (on a consolidated basis) for financial years between 1 January 2025 and 31 December 2026
  • non-EU companies generating EUR 450 million net turnover in the EU for the last two consecutive years with a subsidiary or a branch exceeding EUR 200 million a net turnover in the preceding financial year
  • obligation to adopt a voluntary sustainability reporting standard for companies falling outside the CSRD
  • obligation to adopt a limited assurance standard by 1 July 2027
  • establish one-stop-shop portal where undertakings may access information, guidance and support, including relevant and guidance for reporting

Corporate Sustainability Due Diligence Directive (CSDDD):

  • applies to undertaking with more than 5000 employees and annual turnover higher than annual EUR 1.5 billion; include a review clause on scope extension
  • non-EU companies with a EUR 1.5 billion turnover in the EU
  • value chain due diligence: risk-based approach, with the focus on the areas of companies’ chains of activities where actual and potential adverse impacts are most likely to occur
  • companies will not be required to adopt a climate transition plan
  • no EU harmonised civil liability regime. Liability for non-compliance will be determined at the national level. However, a review clause on the need for an EU harmonised liability regime has been added
  • penalty maximum cap of 3% of net worldwide turnover; the EC to issue guidelines on this matter
  • transposition deadline postponed by another year to 26 July 2028; companies to comply with CSDDD rules by 29 July 2029
  • the EC should publish due diligence guidelines by 26 July 2027

The EP Legal Affairs (JURI) Committee approved the provisional agreement today, 11 December. The EP plenary vote is scheduled on 16 December. The Council must also approve the agreement.

European developments

EFRAG provides technical advice with Draft Amended ESRS to Commission

The Draft Amended ESRS:

  • focus on usefulness of information as a general filter and emphasis on fair presentation
  • simplify the materiality assessment
  • eliminate the preference for direct data in the value chain
  • introduce substantial reliefs, proportionality mechanisms and ad hoc phasing-in for challenging disclosures
  • provide flexibility on how to present the information, and a greater focus on how sustainability matters are managed
  • are shorter, clearer, easier to understand and to implement
  • consist of a 61% reduction of datapoints, whereby all voluntary disclosures have been deleted
  • preserve interoperability with the ISSB as much as possible.

By the end of December, EFRAG will complete the technical advice with the Basis for Conclusions, Cost Benefit Analysis and the Explanatory Note to the standards.

The EC will now prepare the Delegated Act revising the first set of ESRS based on EFRAG’s technical advice.

Read more

 

EFRAG launches ESRS Knowledge Hub

The ESRS Knowledge Hub brings together all key ESRS-related materials in one user-friendly environment and:

  • provides interactive access to the adopted 2023 ESRS, enriched with cross-references, Q&A explanations and XBRL tags
  • includes the draft simplified ESRS and supporting documents
  • includes the VSME standard in interactive format and supporting guidance and tools
  • provides direct linkage to EU legislation, international standards and ongoing EFRAG SRB and EFRAG SR TEG discussions
  • gives historical content and external references for continuity and context.

Read more

 

ESRS Quick Fix DA comes into force

The ESRS ‘Quick Fix’ Delegated Act (DA) was published in the Official Journal of the EU and entered into force on 13 November.

The DA provides a two-year pause on the reporting of additional phase-in data points for certain CSRD wave-1 undertakings.

 

ENVI-ECON Committees reject motion for resolution to object EU Taxonomy ‘Omnibus’ DA

The EP’s Economic and Monetary Affairs (ECON) and Environment, Public Health and Food Safety (ENVI) Committees voted against (68 against, 42 in favour and 1 abstention) a motion for a resolution proposing to object the EU Taxonomy Delegated Act (DA) amending the Disclosures, Climate and Environmental DAs. However, a vote on the objection has been scheduled at the plenary session on 17 December.

The motion for a resolution was tabled by the S&D, the Greens/EFA, and the Left MEPs. The DA aims to simplify key aspects of taxonomy reporting, including introducing a materiality threshold of less than 10% for turnover, streamlining disclosure templates, and easing certain “Do No Significant Harm” (DNSH) criteria.

The Council did not object the DA.

 

Council and Parliament reach deal on deforestation law revision

The Council and the EP have reached a provisional political agreement on a targeted revision of the EU deforestation-free products regulation (EUDR). The deal aims to simplify implementation and postpone the regulation’s application, giving companies, traders, and authorities more time to prepare.

The revised rules will extend the EUDR’s enforcement to 30 December 2026 for large and medium operators, with micro and small operators receiving an additional six-month extension. Responsibility for submitting due diligence statements will fall on operators placing products on the market, while downstream operators will have reduced obligations. Micro and small primary operators will submit a single simplified declaration for traceability.

The EC is tasked with reviewing the regulation by 30 April 2026, assessing its impact and administrative burden, in particular for micro and small operators.

The EP will vote on the deal during its 15-18 December 2025 plenary session. The text agreed must be endorsed by both the EP and Council and be published in the EU’s Official Journal before the end of 2025 for the changes to enter into force.

 

Ombudswoman finds Omnibus I a case of maladministration

The European Ombudswoman found procedural shortcomings in the EC’s urgent preparation of several proposals, notably the Omnibus I on sustainability.

In the preparation of Omnibus I, the EC:

  • reduced the inter-departmental consultation time to less than 24 hours over a weekend, and
  • kept no clear record of a climate consistency assessment

These departures from Better Regulation rules contributed to a finding of maladministration. The Ombudswoman urged clearer justification of urgency and that even accelerated procedures remain transparent, evidence-based, and inclusive.

At the exchange of views with the EP JURI Committee on the 2025 overview report on simplification, implementation, and enforcement, Commissioner Valdis Dombrovskis noted that the EC is preparing its reply; the EC has three months to respond to the Ombudswoman.

Read more

 

Commission provides update on CSDDD Guidelines Consultation

The EC has clarified the timing and process of the public consultation for the Corporate Sustainability Due Diligence Directive (CSDDD) guidelines in response to a written question from MEP Catarina Vieira (Verts/ALE).

MEP Vieira raised concerns about when the consultation would be launched, what steps are being taken to ensure small and medium-sized enterprises can participate, and whether the EC is on track to finalise the guidelines within the shortened timeline proposed in the Omnibus legislation.

Commissioner McGrath confirmed that, while stakeholder consultation is legally required under Article 19 of the directive, it has not yet been possible to launch the consultation due to ongoing legislative negotiations on the Omnibus proposal, which may affect the guidelines’ content and timing. Preparatory steps are underway to ensure an efficient consultation once negotiations are concluded.

 

Commission simplifies rules for sustainable financial products

The EC proposed a set of amendments to the Sustainable Finance Disclosure Regulation (SFDR) to simplify disclosures and improve their usability for retail investors. Among the main changes:

  • entity-level Principal Adverse Impact (PAI) reporting is removed for all except for Financial Market Participants (FMPs) falling under the Corporate Sustainability Reporting Directive (CSRD) threshold, reducing overlap with it
  • product-level disclosures are significantly cut, focusing only on clear, comparable data
  • introduction of a new three-category product system composed of ‘Sustainable’, ‘Transition’, and ‘ESG Basics’ financial products. All three categories require investment of at least 70% in line with their sustainability strategy and apply exclusions like human rights violators, tobacco, etc.
  • lighter data demands and greater reliance on the CSRD data to reduce compliance burden.

The EC also published a set of FAQs to clarify links with other sustainability legislation:

  • revised SFDR relies on the CSRD data and thresholds
  • products with ≥15% Taxonomy-aligned investments automatically meet the 70% requirement

Read more

 

New DAs on ESG rating providers expected in 2026

The EC is set to adopt two DAs on environmental, social and governance (ESG) rating providers in the first quarter of 2026:

Read more

 

International Platform on Sustainable Finance shares its 2025 key deliverables

The International Platform on Sustainable Finance (IPSF) published two key outputs:

1) the 2025 annual report, highlighting major developments in sustainable finance:

  • several jurisdictions are focusing on green taxonomies. The IPFS members are increasingly considering how to embed dynamic elements, like adjusting thresholds or conditional criteria, into the taxonomies
  • transition plans are increasingly used as regulatory tools, with several jurisdictions introducing guidance and requirements to ensure measurable steps toward long-term climate goals.
  • growing alignment between the International Sustainability Standards Board (ISSB) and the ESRS

2) a technical note examining how the DNSH principles are defined and applied across jurisdictions, providing:

  • commonalities and differences in criteria, safeguards, and legal references
  • practical principles to improve implementation and support interoperability across the taxonomy.

The IPSF will continue its work in 2026, focusing on transition frameworks, taxonomies, strategic sectors, and comparability.

Read more

 

COP30 delivered poor results in climate action, according to EP delegation

Leading MEPs attending the Conference of the Parties (COP30) in Brazil regret that only modest results have been achieved on international climate action. The final deal shows a gap between countries’ stated ambitions and the enforceable emissions reductions needed to meet them.

During the discussions, the negotiators:

  • could not agree on a concrete roadmap to phase out fossil fuels
  • agreed on new mechanisms like the ‘Belém 1.5°C mission’ and ‘Global Implementation Accelerator’ that are more about planning and coordination among countries than immediate emissions cuts

The EU played a significant role in the discussions and yet faced strong resistance from BRICS and Arab countries. The EU:

  • secured some progress, including a recommendation to at least triple climate finance by 2035 with USD 300 billion per year and a wider mobilisation target of USD 1.3 trillion
  • reaffirmed its updated National Determined Contribution (NDC) of a 66.25–72.5% emissions cut by 2035.

Read more

International developments

IAASB provides examples to apply ISSA 5000

The International Auditing and Assurance Standards Board (IAASB) released a set of illustrative practitioners’ assurance reports to support the implementation of ISSA 5000, General Requirements for Sustainability Assurance Engagements. The examples show how the standard can be applied in real-world scenarios. They include:

  • five reports with unmodified conclusions covering IFRS S1 and S2 disclosures,
  • multiple reporting frameworks
  • combined assurance engagements, and
  • three reports with modified conclusions (qualified, adverse, and disclaimer)

The guidance helps practitioners address practical and technical issues, promoting consistent and confident application of ISSA 5000.

Read more

 

TNDF stops its technical work in 2026

The Taskforce on Nature-related Financial Disclosures (TNFD) will complete its current technical work by September 2026 and pause any new guidance. This follows the ISSB’s decision to advance its own standard-setting on nature-related risks and opportunities, drawing on the TNFD framework.

The ISSB plans to introduce incremental disclosure requirements not already covered in IFRS S1 and S2, with options including application guidance, amendments, industry guidance, or a new standard. The ISSB is targeting an exposure draft on incremental disclosure requirements in October 2026, in time for the Convention on Biological Diversity COP17.

Read more

National developments

FRC issued ISSA (UK) 5000 for voluntary use in sustainability assurance engagements

The Financial Reporting Council (FRC) issued a UK version of the International Standard on Sustainability Assurance 5000, General Requirements for Sustainability Assurance Engagements. The standard provides comprehensive requirements for conducting sustainability assurance engagements, applicable to both limited and reasonable assurance.

Read more

MEP questions & answers

ESG reporting requirements for small and medium-sized enterprises under CSRD

  • Question by MEP Daniel Obajtek (ECR/Poland)
  • Reply by Commissioner Albuquerque

 

Review of EU Taxonomy Regulation

  • Question by MEP Beatrice Timgren (ECR/Sweden) and Dick Erixon (ECR/Sweden)
  • Reply by Commissioner Albuquerque

 

Public consultation on CSDDD guidelines

  • Question by MEP Catarina Vieira (The Greens/ The Netherlands)
  • Reply by Commissioner McGrath

 

European Commission initiative on competitiveness and excessive red tape

  • Question by MEP Sarah Knafo (ESN/France)
  • Reply by Executive Vice-President Séjourné

 

Extension of scope of EU Deforestation Regulation to new products and new ecosystems

  • Question by MEP César Luena (S&D/Spain)
  • Reply by Commissioner Roswall

Other news

This curated content was brought to you by Vita Ramanauskaité, Accountancy Europe Senior Manager, Head of Sustainability, since 2015. You can send her tips by email, follow her on X and connect with her on LinkedIn.