Accountancy Europe’s has issued factual analysis of the European Commission’s (EC) recent Omnibus proposal focusing on the Corporate Sustainability Reporting Directive (CSRD), the sustainability reporting standards, the Corporate Sustainability Due Diligence Directive (CSDDD), and the Carbon Border Adjustment Mechanism (CBAM). These papers aim to give stakeholders an initial overview of the key proposed changes expected to reshape sustainability reporting and due diligence practices across Europe. Read also our statement on the EC Omnibus sustainability proposal.
This paper will focus on the proposed changes for the CBAM. For more information about the CBAM check out our 2024 CBAM factsheet.
The EC launched the Omnibus sustainability rules simplification package on 26 February 2025. This is the first step of an ambitious simplification agenda to enhance European economic competitiveness. It aims to reduce administrative and reporting burdens on companies and unlocking businesses’ investment potential.
The new simplification agenda set bold targets, including a 25% cut in reporting burdens for companies and 35% for SMEs. The EC expects this effort to boost European companies’ competitiveness while maintaining climate and decarbonisation goals of the Green Deal. The Omnibus package proposes amendments to several sustainability laws. These include the CSRD, the CSDDD, the EU Taxonomy for sustainable activities, and the CBAM.
The Omnibus introduces a significant change in the CBAM scope. While the product categories remain the same, it proposes that a mass-based threshold replaces the de-minimis threshold of €150. This new threshold will be designed to still ensure that 99% of embedded emissions on imported goods fall under the CBAM. The proposed initial threshold is 50 tonnes per importer, per type of imported goods covered by CBAM. According to the EC, this will exclude 90% of importers currently required to purchase CBAM certificates. The EC calculated the mass-based threshold on data obtained during the transition period.
As a mass-based threshold increases the risk for manipulation, the Omnibus also includes rules to monitor and penalise attempts to bypass registration or the purchase of CBAM certificates.
It is important to note that the EC proposals are not final. The EC will submit the proposal to the two co-legislators – the European Parliament (EP) and the Council of the European Union – for their review, input and adoption. These institutions hold the power to amend the currently proposed Omnibus sustainability package.
Download the factsheet from the ‘download’ section at the top right of this webpage.
