1. Overview

The EU Omnibus Simplification Package, published in early 2025, is a legislative initiative by the European Commission intended to streamline and reduce administrative burdens associated with EU sustainability regulations. It primarily amends implementation timelines and requirements under the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

This package was developed in response to stakeholder concerns over the complexity, cost, and timing of existing reporting obligations, especially for small and medium-sized enterprises (SMEs). It also reflects strategic guidance from EU-level economic policy documents, including the Draghi Report on European Competitiveness (2024) and the Budapest Declaration on the New European Competitiveness Deal.

1.1 Key Changes Introduced

Area	Description
Reporting Timelines	Postponement of CSRD and CSDDD application deadlines by up to two years.
Scope of Applicability	Large companies with fewer than 1,000 employees and all listed SMEs are exempted from CSRD reporting.
Reporting Standards (ESRS)	Simplified European Sustainability Reporting Standards with fewer mandatory datapoints; elimination of sector-specific standards.
SME Reporting	Introduction of a voluntary reporting standard for SMEs, based on EFRAG’s VSME draft.
Assurance Requirements	Assurance obligations remain at the “limited” level; the shift to “reasonable” assurance has been cancelled.
EU Taxonomy Reporting	Opt-in regime introduced for mid-sized companies with net turnover under EUR 450 million.

The simplification measures are designed to reduce regulatory burden while preserving the core objectives of EU sustainability policies, particularly those under the European Green Deal and the Sustainable Finance Action Plan. The Commission has committed to maintaining coherence with international reporting frameworks and avoiding unnecessary duplication or reporting overlap.

2. Why This Matters

The EU’s sustainability reporting framework, led by the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), was designed to align financial and corporate accountability with the objectives of the European Green Deal. These directives require companies to report on environmental, social, and governance (ESG) impacts, risks, and opportunities across their operations and value chains.

However, as implementation began, feedback from companies, industry associations, and Member States highlighted challenges related to timing, complexity, and administrative burden—especially for mid-sized firms and listed SMEs. The Omnibus Simplification Package responds to these concerns by deferring key obligations and narrowing the scope of mandatory reporting.

2.1 Contextual Drivers

The simplification package is part of a broader political and economic recalibration within the EU. Several factors contributed to this shift:

Competitiveness concerns: The Draghi Report on European Competitiveness (2024) emphasized the need for a regulatory environment that fosters resilience and reduces unnecessary compliance costs.
SME advocacy and feedback: Through public consultations and stakeholder forums, many businesses, particularly SMEs, called for scaled-down or voluntary ESG reporting frameworks.
Policy coordination: The Budapest Declaration on the New European Competitiveness Deal (November 2024) called on the Commission to reduce EU reporting burdens by at least 25% by mid-2025.
Geopolitical pressures: Energy cost volatility, supply chain instability, and regulatory divergence with other jurisdictions prompted the EU to review its sustainability timelines and enforcement approach.

2.2 Implications of Delay and Simplification

The changes introduced are not merely technical adjustments. They carry broader implications for sustainability governance in the EU:

Transparency trade-offs: Fewer companies will be required to publish structured sustainability data, creating potential gaps in ESG disclosure and comparability.
Reduced investor insight: Delayed access to consistent ESG data could impair sustainable finance decisions and limit risk visibility across the market.
Shifting expectations for SMEs: The removal of mandatory reporting obligations for listed SMEs reduces compliance pressure but also limits accountability and stakeholder engagement.
Adjustment for MRV systems: Monitoring, reporting, and verification (MRV) practitioners will need to account for lower data availability, particularly in value chains involving exempted entities.

The simplification package marks a strategic rebalancing: aiming to maintain long-term sustainability objectives while reducing immediate regulatory burdens. How effectively this balance is managed will determine its credibility and impact in practice.

3. What’s Changing – At a Glance

The Omnibus Simplification Package makes targeted amendments to the CSRD and CSDDD, focusing on deferring timelines, narrowing scope, and simplifying reporting requirements. The following table summarizes the main changes:

3.1 CSRD Amendments

Element	Original Requirement	New Status (2025 Omnibus Package)
Application timeline (2nd wave)	Large undertakings (non-PIEs, >500 employees) report in 2026 (FY 2025)	Delayed to 2028 (FY 2027)
Application timeline (3rd wave)	Listed SMEs report in 2027 (FY 2026)	Delayed to 2029 (FY 2028); voluntary opt-out extended
Scope	Large undertakings and listed SMEs	Threshold raised: only large companies with >1000 employees remain in scope
Assurance level	Gradual move from limited to reasonable assurance	Fixed at limited assurance; no future upgrade
Sector-specific standards	Required by June 2026	Eliminated; no sector-specific standards to be developed
Value chain reporting cap	Applied only to SMEs in value chains	Extended to all entities <1000 employees; broader protection
SME reporting (voluntary)	Not included in mandatory framework	Voluntary standard (based on EFRAG VSME) to be adopted by Commission
EU Taxonomy KPIs	Mandatory for all in scope	Optional for companies with <EUR 450 million turnover

3.2 CSDDD Amendments

Element	Original Requirement	New Status (2025 Omnibus Package)
Transposition deadline	July 2026	Delayed to July 2027
Application timeline (Phase 1)	July 2027 (companies >5000 employees, >EUR 1.5bn turnover)	Delayed to July 2028
Application timeline (Phases 2–3)	July 2028 and July 2029 respectively	Remain unchanged as of current proposal

These changes significantly reduce near-term compliance obligations for many companies, particularly mid-sized firms and listed SMEs. However, they also reduce the volume and coverage of sustainability information expected in the coming years.

4. Implications by Stakeholder

The simplification package affects stakeholders in distinct ways. Below is a practical summary by group:

4.1 Companies

In-scope (Large Enterprises):

Fewer required disclosures under simplified ESRS.
Extended compliance deadlines (2028–2029).
Continued use of limited assurance only—no escalation.

No longer in scope (Listed SMEs, mid-sized firms):

No mandatory CSRD reporting.
Option to adopt a voluntary SME standard.
Risk of investor disengagement without disclosure.

Multinationals:

Reduced supply chain data from exempted suppliers.
May need proprietary methods to fill value chain gaps.

4.2 MRV Practitioners

Data Shortfalls: Less structured ESG data, especially from SMEs.
Timeline Shifts: Updated planning needed for assurance, engagement, and verification cycles.
Tool Demand: Opportunity to support voluntary adopters with simplified MRV templates and platforms.

4.3 Investors and Financial Institutions

Reduced Transparency: More difficulty benchmarking ESG performance across firms.
SFDR Impacts: Challenges meeting disclosure obligations without upstream data.
Voluntary Reporting: Growing importance of non-mandatory ESG signals in portfolio screening.

4.4 Civil Society and Advocacy Groups

Less Access to Data: Harder to monitor environmental and social impacts.
Weaker Enforcement Tools: Fewer touchpoints for accountability, especially in smaller firms.
Strategic Advocacy Needed: Must focus on promoting voluntary transparency and national-level tracking.

5. Key Concerns and Trade-Offs

Trade-Off	Concern and Implication
Transparency vs. Simplicity	Concern: Fewer entities report; structured ESG data becomes scarce. Implication: Hinders comparability and weakens public accountability.
Accountability vs. Short-Term Relief	Concern: Delayed timelines and reduced requirements slow Green Deal progress. Implication: Weakens momentum in ESG system development and internal reforms.
Policy Coherence vs. Flexibility	Concern: Diverging implementation across Member States. Implication: Compliance becomes fragmented, especially for multinational entities.
Cost Reduction vs. Data Reliability	Concern: Capping assurance at limited level may reduce data trustworthiness. Implication: Investors and stakeholders face higher uncertainty and less assurance.
SME Support vs. Sustainability Momentum	Concern: Exempting SMEs may discourage proactive sustainability efforts. Implication: Long-term ESG integration and maturity may stagnate for this segment.

6. What You Can Do

The Omnibus Simplification Package reduces formal obligations but does not eliminate the need for credible, transparent sustainability practices. Below are recommended actions by stakeholder group.

6.1 For Companies

Situation	Recommended Action
In-scope under revised CSRD	Use additional time to strengthen internal ESG systems and prepare for reporting in 2028–2029.
Exempted (e.g., listed SME)	Consider voluntary adoption of the EFRAG VSME standard to maintain credibility with investors and partners.
Multinational with complex supply chain	Develop your own ESG data collection protocols to offset data loss from exempted suppliers.
Seeking to maintain investor trust	Continue disclosing key sustainability metrics even if not legally required, to demonstrate proactive governance.

6.2 For MRV and Data Practitioners

Challenge	Recommended Action
Data gaps from exempted entities	Offer simplified data collection templates or low-cost tools for voluntary reporting.
Reduced standardization	Align tools with voluntary frameworks (e.g., GRI, CDP) to facilitate continuity and comparability.
Delayed assurance requirements	Continue engaging clients on assurance readiness and methodology improvements.
Planning for variable data quality	Establish tiered MRV strategies that adapt to differing levels of data granularity and reliability.

6.3 For Investors and Financial Institutions

Gap or Risk	Recommended Action
Limited ESG data from SMEs	Encourage or incentivize voluntary disclosure through financing terms or investor coalitions.
Need to maintain SFDR compliance	Invest in internal ESG estimation models where upstream data is unavailable.
Managing portfolio sustainability	Use alternative indicators (e.g., certifications, climate commitments) where standardized reports are missing.

6.4 For Civil Society and Policy Advocates

Concern	Recommended Action
Transparency setbacks	Track implementation at Member State level and promote voluntary transparency practices.
Reduced oversight leverage	Develop third-party monitoring tools and ESG scorecards tailored to sectors or regions.
Need to maintain pressure	Engage in EU consultations, support national accountability campaigns, and document case studies.

These actions support continuity in sustainability leadership even under lighter regulation. Voluntary frameworks, stakeholder expectations, and evolving market standards continue to shape practice beyond legal compliance.

7. Further Reading and Resources

The following resources provide authoritative guidance, technical documentation, and policy context for stakeholders navigating the implications of the EU Omnibus Simplification Package.

7.1 Official Legislative Documents

Title	Source
Proposal to amend CSRD and CSDDD thresholds and reporting requirements	European Commission – February 2025
Proposal to postpone CSRD and CSDDD application deadlines	European Commission – April 2025

7.2 Related EU Sustainability Frameworks

Directive/Standard	Purpose and Use
Corporate Sustainability Reporting Directive (CSRD)	Defines who must report on ESG, when, and how.
Corporate Sustainability Due Diligence Directive (CSDDD)	Requires large firms to manage human rights and environmental risks in their value chains.
European Sustainability Reporting Standards (ESRS)	Detailed disclosure standards under CSRD, developed by EFRAG.
Sustainable Finance Disclosure Regulation (SFDR)	Defines ESG disclosure obligations for financial market participants.

7.3 Voluntary and Transitional Reporting Resources

Resource	Access/Use
EFRAG VSME Draft Standard	EFRAG Website – Voluntary sustainability reporting standard for SMEs.
EU Taxonomy User Guide	EU Platform on Sustainable Finance – Explains classification of sustainable activities.
Global Reporting Initiative (GRI) Standards	Widely adopted voluntary ESG disclosure framework aligned with CSRD principles.
CDP Disclosure Platform	Used by companies to report on climate, water, and forest-related risks voluntarily.

7.4 Implementation and Technical Tools

Tool/Guide	Application
EU CSRD Factsheets	Simplified summaries of obligations and reporting timelines.
MRV Templates (IEF-recommended)	Templates for emissions tracking, assurance planning, and voluntary reporting.
EU Commission Q&A on Omnibus Package	Clarifies legal and transitional provisions.

8. What This Means Going Forward

The Omnibus Simplification Package marks a recalibration of the EU’s sustainability reporting agenda - not a reversal. While the scope of mandatory compliance has been narrowed and timelines extended, the underlying strategic goals of the CSRD and CSDDD remain in place. This shift offers both opportunities and risks for the implementation of environmental, social, and governance (ESG) practices across Europe.

8.1 Strategic Implications

Reporting is delayed, not dismantled: Large companies will still need to prepare for comprehensive ESG disclosures, just on an extended timeline. For others, especially SMEs, the pathway is now voluntary - but not irrelevant.
Voluntary standards become critical: With many companies no longer legally obligated to report, voluntary frameworks like EFRAG’s VSME or GRI will play a key role in maintaining ESG visibility across markets.
MRV systems must adapt: Monitoring and verification practices will need to accommodate variable data quality and coverage. This includes building modular systems that work for both regulated and voluntary disclosures.
Investors and market actors must push transparency: Without regulatory backing for comprehensive ESG data, stakeholders in finance, procurement, and civil society must maintain pressure for meaningful sustainability practices.
National and sectoral leadership will matter more: As EU-level requirements become more flexible, national governments and industry coalitions have greater room to lead on implementation, standard-setting, and incentives.

8.2 Forward Action

Prepare for eventual compliance: Even if not currently in scope, companies should consider using the additional time to develop ESG processes, systems, and internal capacity.
Support voluntary adopters: Practitioners and tool developers should prioritize accessible, low-burden solutions for SMEs and mid-sized firms seeking to report voluntarily.
Track evolving guidance: As the European Commission and EFRAG continue refining standards and tools, staying current with updates will be essential.

The simplification package reflects a realignment of ambition with feasibility. Whether this becomes a strategic step forward or a missed opportunity will depend on how effectively actors across sectors use the space it creates.