What is the CSRD Omnibus proposal?

In January 2025, the European Commission issued a Competitiveness Compass, setting the vision for strengthening the EU's competitiveness and making the EU's economy more prosperous. The Commission also published a work program announcing a series of “omnibus” packages. In February 2025, the European Commission presented a first package of two omnibus proposals. These proposals include modification of some elements of the Corporate Sustainability Due Diligence Directive (CSDDD) the EU Taxonomy and the Corporate Sustainability Reporting Directive (the CSRD) among other EU legislation. Here, we’re focusing on how the proposal may impact the CSRD.

Key points include:

·       The European Commission’s Omnibus package includes proposals for simplification of the Corporate Sustainability Reporting Directive (CSRD) to reduce the complexity of EU requirements for businesses, notably SMEs and small mid-caps (SMCs).

·       Despite rumors to the contrary, the Omnibus confirmed a commitment to preserve double materiality and limited assurance.

·       The changes will take time to be passed into law, and the amended directives are not directly applicable throughout EU Member States. They require incorporation to national laws, which in turn requires more time and adds planning and legal complexities.

Read on for more detail.

·       Set new thresholds with listed SMEs and small mid-caps (SMCs) falling out of scope (see table 1)

·       Change the timing for first CSRD reports for some organizations (see table 2).

·       Retain the limited assurance requirement but remove plans to transition assurance standards to reasonable assurance.

·       The double materiality analysis (DMA) remains unchanged.

·       Discontinue plans to introduce sector-specific standards. 

·       Increase thresholds for non-EU companies.

·       Flag plans to revise and update the current European Sustainability Reporting Standards (ESRS), including a reduction of the required data points and prioritization of quantitative data points over narrative data points.

·       The changes will take time to be passed into law, and the amended directives are not directly applicable throughout EU Member States. They require incorporation to national laws, which will take more time and add planning and legal complexities.

*The stated objective of presenting two separate proposals—one to modify thresholds and one to postpone reporting—is to provide clarity and avoid a situation in which undertakings prepare reports for FY2025 or FY2026 only to be later exempted if the CSRD thresholds are modified. This explains why SMEs are excluded under the thresholds proposal but are still considered in the timing proposal.  

IBM Envizi offers a comprehensive solution for reporting under the CSRD, and continues expanding the solution with updates and enhancements. The EU Omnibus proposals that were released in February 2025 do not impact the product development roadmap.

The Omnibus package includes a reference to plans to modify the ESRS data points. If these changes are adopted as legal requirements, they will be integrated into Envizi as part of the regular release process.

The European Union Commission started simplifying the CSRD and the related European Sustainability Reporting Standards (ESRS), with the Omnibus proposals marking the initial phase of this endeavor. However, revising existing legislature is an inherently resource-intensive and time-consuming activity. This inherent ambiguity can pose considerable challenges for organizations subject to potential alterations in their reporting obligations, especially when considering the substantial effort required to align data and systems with the CSRD's reporting prerequisites.

Companies may be taking different approaches while awaiting clarity from the Omnibus proposals, but having a comprehensive reporting approach consistent with relevant topics for their company is imperative including:

1. Cross-jurisdictional perspective: considering the regulatory environment, market dynamics and economic factors of all the relevant jurisdictions for their organizations. Help ensure that there are plans to comply with local laws and standards that are relevant to each specific market.
2. Internal management perspective: ensuring that reporting planning aligns with strategic business objectives and operational needs. It's about ensuring that the information gathered and disseminated supports decision-making processes, risk management strategies, performance measurement and resource allocation.

This holistic reporting approach can use technology to enable reporting in a more effective and efficient manner. For instance, the Ikano Group, an Envizi client, decided to continue its partnership with Ikano Insight to uphold its existing CSRD reporting progression. A comprehensive account of their CSRD reporting experience is detailed in the accompanying case study.

Organizations like Ikano Group acknowledge that the case for corporate sustainability transcends reporting, incorporating aspects such as:

·      Risk mitigation (regulatory, supply chain, climate, reputational)

·      Efficiency enhancements (energy, materials, waste minimization)

·      Revenue expansion (green products, sustainable financing)

Simon Taylor, Marketing Director at Ikano Insight, emphasizes the importance of perceiving reporting requirements as opportunities rather than obligations, advocating for a strategic paradigm shift that prioritizes sustainability. This perspective, he suggests, is integral to fostering a culture that sees sustainability reporting not just as a compliance exercise, but as a strategic driver of business value.

“Seeing the reporting requirements as an opportunity rather than a requirement is key—it is a mindset shift driven by an integrated business strategy that prioritizes sustainability,” says Simon Taylor, Marketing Director, Ikano Insight.

As organizations navigate the evolving CSRD landscape, the Omnibus proposal offers both simplifications and new considerations. While the reduction in scope and delayed disclosure timelines can ease compliance requirements for some, the continued emphasis on double materiality and limited assurance underscores the EU's ongoing commitment to sustainability disclosures.

Organizations must stay adaptable, using technology and refining reporting strategies to align with long-term sustainability goals.

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Last updated on: 25 March 2025

The information that is contained in this website is provided for informational purposes only, and cannot be construed as legal advice on any matter.