21 November, 2025

The omnibus journey has been long, and we’ve covered many of the twists along the way. Last week marked another major stepping stone on the path to a final conclusion.  

The European Commission launched the first Omnibus package on 26 February 2025 as part of its simplification agenda for the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). A “quick fix” followed in summer, consultations closed in September, and negotiations stalled in October when Parliament blocked the trilogue mandate. After months of regulatory uncertainty, the EU Parliament adopted its revised Final Position on the second Omnibus package on 13 November 2025.

This provides confirmation of many of the expected changes: an overall watering down of CSRD and CSDDD, which includes removing transition plans and shrinking the scope of due diligence.

A brief summary of what has changed includes:

–Higher thresholds for CSRD: now only for companies with more than 1,750 employees and €450m turnover, dramatically narrowing the scope.

–Assurance scaled back: mandatory reasonable assurance replaced by limited assurance.

–Voluntary standards: smaller undertakings can opt in, but only if they choose to.

–CSDDD narrowed: due diligence now covers own operations, subsidiaries, and direct partners only. Mandatory climate transition plans? Gone.

It’s undeniable that the prospect of these changes may be appealing to many hard-pressed companies struggling to manage their reporting obligations.

But we believe this would be a mis-step. The relevance of sustainability issues remains unchanged, regardless of whether you are required to report on them. The reality is that social and environmental issues are not only urgent and pressing, they are also intricately intertwined with business stability, resilience and success.

It’s also the case that lower regulation does not mean lower expectations. These weaker rules may even increase demand for transparency and accountability from customers, investors and civil society.

And, businesses tempted to step back as a result of these changes are likely to find that their competitors continue to raise the bar. Businesses that are already reporting have set a high standard and many will continue to do so, providing credible data for stakeholders to review and to feed back into their own strategy and planning.

Our view: don’t let the changes to the rules hold you back from the reporting that many of your stakeholder will expect, and which will drive meaningful change beyond compliance. And if you would like to explore how to stay ahead, we would love to talk.

By Sarah Forero