On 26 February 2025, the European Commission presented the first part of the so-called "omnibus" package of amendments, which was announced in January. This is a legislative initiative aimed at simplifying and making the setting European Union rules on sustainability reporting (hereinafter referred to as the "comprehensive package" or "Commission proposal").
Document COM_2025_80 represents proposal for a directive of the European Parliament and of the Council amending Directives (EU) 2022/2464 (CSRD) and (EU) 2024/1760 (CSDDD) as regards the dates from which Member States are to apply certain corporate sustainability reporting and due diligence requirements.
- The main objective of the proposal is simplification and acceleration of European legislation in line with the Commission Communication "A simpler and faster Europe: Communication on implementation and simplification". The Commission underlines the need bold steps to streamline and simplify EU, national and regional rules.
- The proposal responds to stakeholders' concerns regarding administrative burden arising from the CSRD and CSDDD. Some stakeholders called for extensive changes and postponements, while others stressed the need for legal certainty and were against reopening the directive, focusing instead on implementation.
- The CSRD entered into force on 5 January 2023 and strengthened and modernised corporate reporting obligations, contributing to financial stability and environmental integrity. It requires companies within its scope to report on sustainability in accordance with European Sustainability Reporting Standards (ESRS).
- Important aspects of the CSRD are the provisions on verification about reporting information in the value chainCompanies must disclose their sustainability information together with a limited assurance opinion from a statutory auditor or independent assurance provider, with the expectation that reasonable assurance could become a requirement in the future under certain conditions.
- CSRD is introducing value chain limit, which stipulates that ESRSs must not contain reporting requirements that would require small and medium-sized enterprises (SMEs) in their value chain to disclose information beyond what should be disclosed under an appropriate standard for listed SMEs.
- Proposal postpones the application dates certain CSRD requirements. For all companies within the scope of the CSRD, which was to apply from 2025, a two-year postponement of sustainability reporting requirements.
- Similarly, it is proposed Postponement of the date of application of the measures foreseen in the CSDDD Directive.
- The proposal is in line with EU policy on strengthening competitiveness and simplifying the regulatory environmentThe legal basis for the Directive is Articles 50 and 114 TFEU.
- The Commission plans adopt the necessary delegated act as soon as possible, no later than six months after the entry into force of this Directive, in order to simplify the reporting frameworkThe revision of the delegated act will significantly reduce the number of mandatory ESRS data points.
- Undertakings covered by both the CSRD and the CSDDD are not required to report any information under the CSDDD in addition to what they are required to report under the CSRD.
Document COM_2025_81 represents Proposal for a Directive of the European Parliament and of the Council amending Directives 2006/43/EC (Audit Directive), 2013/34/EU (Accounting Directive), (EU) 2022/2464 (CSRD) and (EU) 2024/1760 (CSDDD) as regards certain requirements for corporate sustainability reporting and due diligence.
- Like COM(2025) 80 final, this proposal also pursues the objective of simplification and burden reduction in the area of sustainability reporting and due diligence. Responds to calls from stakeholders for streamlining reporting requirements.
- Proposal limits the scope of mandatory sustainability reporting only on large companies with an average of more than 1,000 employeesThis revised threshold should bring CSRD closer to CSDDD.
- Listed SMEs are excluded. from the scope of mandatory sustainability reporting. The possibility for listed SMEs to benefit from a two-year exemption from the reporting obligation is also abolished.
- An option is introduced optional sustainability reporting standards for SMEs that do not fall within the scope of the obligations (VSME standard)The aim is to provide SMEs with a simple tool to provide sustainability information to banks, large companies and other stakeholders.
- Requirements for obtaining information from SMEs in the value chain are being limitedReporting companies should not require SMEs with fewer than 1,000 employees to disclose information beyond what would be required to be disclosed under the optional standards.
- Changes are proposed in obligations related to the value chain under the CSDDD, with due diligence generally limited to the companies' own operations, the operations of their subsidiaries and, where related to their chains of activities, to the operations of their direct business partners.
- The obligation is abolished. to terminate business relations in the case of actual and potential adverse impacts within the CSDDD.
- Changes are being introduced in harmonization of CSDDD, the scope of maximum harmonisation is extended to several other provisions regulating essential aspects of the due diligence process.
- The deadline for transposition of the CSDDD is being postponed by half a year. Member States are to adopt the necessary measures by 26 July 2027 and apply them from 26 July 2028 for the largest companies.
- The provisions relating to companies' transitional climate change mitigation plans in order to ensure greater legal certainty and alignment of the CSDDD with the sustainability reporting regime under the CSRD.
- Provisions relating to: civil liability within the framework of the CSDDD, specific requirements regarding representation in legal proceedings and the extraterritorial application of mandatory rules are removed.
- Cancelled first revision clause in CSDDD.
- The proposal also includes changes to Audit guidelines a Accounting guidelines, which are related to limiting the scope of sustainability reporting obligations.
Document COM_2025_87_1 represents proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2023/956 on the Carbon Border Offset Mechanism (CBAM) with a view to simplifying and strengthening it.
- The aim of the proposal is to reduce administrative burden resulting from the CBAM, especially for SMEs, while preserving its environmental objectives.
- It is introduced new exemption from CBAM obligations for importers of small quantities of CBAM goods, specifically for shipments with with a net weight not exceeding 50 tonnes.
- They are getting easier reporting obligations by introducing changes to the portal for registering operators and installations in third countries.
- It is introduced registration of accredited verifierswho will have access to the CBAM registry and will be able to perform certain relevant tasks to facilitate reporting obligations.
- Member States' competence in the field is being strengthened monitoring and enforcement CBAM.
- The rules regarding calculation of embedded emissions, in particular with regard to input materials (precursors) that have already been subject to the EU ETS or another carbon pricing system.
- Rules are being simplified for application of the carbon price paid in a third country.
- The provisions relating to registration of operators and installations in third countries.
- Changes are being introduced in submitting a CBAM statement.
- The rules for purchase, transfer and cancellation of CBAM certificates.
- The provisions on exchange of information between customs authorities and CBAM authorities.
- Specific rules are being introduced for monitoring and enforcement of the exemption threshold.
- The rules regarding sanctions for non-compliance with the CBAM regulation.
- FROM CBAM range excludes uncalcined kaolin clays.
Overall, these documents represent the European Commission's legislative proposals aimed at simplification and reduction of administrative burden arising from existing legislation in the field sustainability reporting (CSRD), due diligence (CSDDD) and carbon border offset mechanism (CBAM)The proposals include changes to the scope, implementation dates, reporting requirements and enforcement obligations, with the aim of increasing proportionality and competitiveness of European companies while maintaining environmental objectives. Spring



