Omnibus I: the final agreement — what you need to know

The European Parliament and the Council of the EU have reached a final agreement on the Omnibus I package, which significantly reduces the scope of the main European sustainability regulations. As your strategic partner in ESG management, we want to give you the full picture so you can make informed decisions about your obligations.

What happened?

After months of trilateral negotiations, Parliament and Council reached a definitive agreement that substantially amends the CSRD, CSDDD, and other sustainability frameworks. The agreement was pending formal approval by both institutions, scheduled for 16 December, and was expected to pass with backing from the EPP and other political groups.

The most important changes

1. Drastic reduction in CSRD scope

New thresholds:

• Only companies with more than 1,000 employees and turnover above €450 million
• Previous threshold: 250 employees

What this means:

• Approximately 90% of initially covered companies would be exempt
• However, the agreement includes a review clause: legislators could reconsider this scope in the future

Fundamental change:

• Mandatory climate transition plans are entirely removed as a requirement

2. CSDDD: only for the largest companies

New thresholds:

• Only companies with more than 5,000 employees and turnover above €1.5 billion
• Previous threshold: 1,000 employees and €450 million

Key modifications:

• Removal of the mandatory climate transition plan requirement
• Penalties capped at 3% of global turnover
• Mandatory compliance delayed until July 2029

Due diligence changes: The restriction to Tier-1 suppliers has been removed, but new rules allow a minimum scope instead of full value chain mapping. Companies have broad flexibility to prioritise direct partners, even when severe impacts may exist at other tiers — this significantly reduces due diligence expectations in practice.

3. EUDR: 12-month delay

The EU Deforestation Regulation (EUDR) is delayed by 12 months:

• New application date: 30 December 2026
• The final Parliament vote was scheduled for 16 December, alongside Omnibus I

4. ESRS: significant simplification

EFRAG published its final proposal to revise the European Sustainability Reporting Standards:

• 61% fewer mandatory data points
• Simplified materiality assessments
• Reduced value chain data requirements
• Removal of voluntary disclosures
• Introduction of exceptions for “excessive cost or effort”

Estimated economic impact:

• 44% reduction in reporting costs
• Annual savings for large companies: approximately €1.1 million
• Annual savings for smaller companies: approximately €150,000

What does this mean for you?

If you were preparing for CSRD

Companies between 250 and 1,000 employees: If you do not exceed the new thresholds (1,000 employees and €450 million turnover), you will most likely be exempt from the obligation. Bear the review clause in mind, however.

Companies above the new thresholds: You remain subject to CSRD, but with simplified requirements (61% fewer data points) and no obligation for climate transition plans.

If you are part of a supply chain

Here is the nuance: even if you are not directly obligated by CSRD or CSDDD, your large customers may still be — and they will very likely continue asking you for sustainability data as part of their due diligence.

The difference is that they now have more flexibility in choosing which suppliers they request data from. That does not mean they will stop asking.

If you work with forestry products

The EUDR delay gives you 12 additional months, but the date is confirmed: 30 December 2026. Use this time to prepare your traceability and documentation systems.

Our strategic recommendation

This agreement represents a significant step back from the EU’s sustainability ambitions, framing CSRD and CSDDD as cost burdens rather than strategic advantages.

But here is what matters: the market reality has not changed.

Companies that generate real value from ESG do not do it solely because a directive requires it. They do it because:

• Banks and insurers already integrate ESG criteria into their decisions, regardless of Omnibus
• Global supply chains will continue demanding sustainability information from their suppliers
• B2B buyers and consumers make decisions based on ESG performance
• Operational efficiency and climate risk management generate tangible value

The reduction in legal obligations does not mean your stakeholders will stop asking for information. In fact, many large companies will continue reporting voluntarily to maintain their competitive position.

What to do now

1. Assess your new status Review whether, under the new thresholds, you remain a mandatory subject.

2. Do not stop entirely Even if you are exempt from the legal obligation:

• Your large customers may still request data from you
• ESG criteria are embedded in financing and insurance decisions
• The information you have already gathered has strategic value

3. Take advantage of the simplifications If you remain obligated, the good news is:

• 61% fewer mandatory data points
• More flexibility on materiality and value chain
• Significantly reduced reporting costs

We are still here

We are monitoring the legislative process closely and will keep you updated on:

• The final legal texts once published
• New EFRAG implementation guidelines
• Any relevant developments in Spanish transposition

The European regulatory landscape is changing fast, but our mission remains the same: helping you navigate these changes with confidence and turning sustainability into a real competitive advantage, not just a compliance exercise.