Omnibus factsheets
Accountancy Europe has issued two factual analyses of the Omnibus Directive1 amending the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD). These two papers aim to provide stakeholders with an overview of the key changes to sustainability reporting and assurance thereon, as well as due diligence requirements across Europe.
Read our statement on the political agreement.
For more information on the Omnibus package, check our Sustainability Omnibus Hub.
Background information
The European Commission (EC) launched the Omnibus on Sustainability proposal on 26 February 2025 as part of its agenda to simplify EU sustainability legislation and reduce administrative burdens for companies. It streamlines sustainability reporting requirements while safeguarding the objectives of the EU Green Deal. To this end, it amends key provisions of the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Taxonomy Regulation. Following negotiations with the Council of the European Union (Council), the European Parliament (EP) adopted the final legal text on 16 December 2025.
CSRD
The Omnibus Directive significantly narrows the CSRD scope; only large undertakings with more than 1,000 employees and a net annual turnover exceeding €450 million are required to report. Listed Small and Medium-sized Enterprises (SMEs) are fully exempt, marking a substantial shift from the original framework. Among other changes:
- scope for third-country companies: non-EU undertakings generating € 450 million net annual turnover in the EU (individually or on a consolidated basis) for each of the last two consecutive years, and having a subsidiary or a branch in the EU exceeding € 200 million net turnover
- value chain cap: safeguards have been introduced for companies in the value chain – companies that fall below the threshold of 1,000 employees; the information requests are limited to the information included in the voluntary sustainability reporting standard
- permitted information omission: companies may omit certain information, such as commercially sensitive, classified or IP-related information if certain conditions are met
- digital tagging: the requirement is postponed until detailed rules are adopted
- voluntary reporting standard: the EC shall adopt voluntary sustainability reporting standards for undertakings with less than 1000 employees on average
- sustainability assurance: limited assurance remains mandatory with a limited assurance standard to be adopted no later than 1 July 2027
- digital support: the EC shall establish a one-stop-shop portal with information, guidance and support, including templates, linked to sustainability reporting
CSDDD
The Omnibus I Directive introduces substantial changes to the CSDDD, including higher scope thresholds, adjustments to the due diligence framework, changes to enforcement and liability provisions, and a revised application timeline.
Member States must transpose the Directive by 26 July 2028. The amended rules will apply from 26 July 2029, while the obligation for in-scope companies to publish on their website an annual statement on sustainability due diligence matters will apply to financial years starting on or after 1 January 2030.
- narrowed scope: the scope of the CSDDD is narrowed by higher applicability thresholds. The Directive applies to EU companies with more than 5,000 employees and a net worldwide turnover exceeding EUR 1.5 billion, and to non-EU companies generating more than EUR 1.5 billion in turnover within the EU
- amended due diligence framework: the risk-based due diligence approach is retained, with modified operational requirements. Companies must conduct a scoping exercise based on reasonably available information to identify areas across their operations, subsidiaries, and relevant business partners where adverse impacts are most likely and most severe. In-depth assessments are limited to these areas. Information requests to business partners are restricted to what is necessary, with additional safeguards for partners employing fewer than 5,000 employees
- changes to penalties and civil liability: penalties for non-compliance are limited to a maximum of 3% of net worldwide turnover, and civil liability is narrowed by deferring to national law
- maximum harmonisation: full harmonisation is extended to additional provisions governing the core elements of the corporate due diligence process, meaning that Member States can no longer introduce national rules diverging from the Directive in those areas
- other key changes: the obligation to adopt climate transition plans is removed, ‘stakeholders’ definition is narrowed, stakeholder consultation obligation is tightened, termination of a business relationship is no longer required, suspension is the only last-resort measure, monitoring frequency is reduced to once every five years.
