Nasdaq Sustainability Solutions

    omnibus webinar header

    Resource Hub

    EU Sustainability Omnibus

    On 16 December 2025, European legislative bodies reached a consensus on the Sustainability Omnibus text, ten months following its initial proposal. This agreement seeks to streamline the directives concerning corporate sustainability reporting (CSRD) and corporate sustainability due diligence (CSDDD). Reporting obligations have been significantly reduced, and the commencement of disclosures is postponed for numerous reporters. Discover resources and insights below on how your company can adeptly manage these changes. Nasdaq Sustainability Solutions is your partner; we can equip you with the latest insights and help you navigate these dynamic regulatory landscapes.

    Directive (EU) 2026/470 (EU Sustainability Omnibus)

    Key Highlights

    • Il Sustainability Omnibus mira a semplificare il panorama normativo per le aziende, continuando a sostenere l'obiettivo del Green Deal europeo.
    • Limiting Scope: The scope of companies required to report under the CSRD and the CSDDD has been greatly reduced. The thresholds for required reporting are limited to the following:
      • CSRD: companies with over 1,000 employees and with a net turnover exceeding €450 million
      • CSDDD: companies with over 5,000 employees and who have had a worldwide net turnover of more than €1.5 billion 

    Who does the Sustainability Omnibus affect?

    • Compliance with CSRD will now only be required of companies with a net turnover exceeding €450 million and with an average of more than 1,000 employeesnel corso dell'anno finanziario. Ciò implica che tutte le aziende più piccole sono ora escluse dall'ambito della direttiva.
    • The scope of companies required to report to CSRD will be reduced by approximately 90%.
    • Companies still in scope include a portion of the former Wave One, Wave Two and Non-EU or Wave Four, with SMEs now excluded entirely.
    • Compliance with the Corporate Sustainability Due Diligence Directive (aka CSDDD or CS3D) will now be required only of companies with a yearly average of more than 5,000 employees and who have had a worldwide net turnover of more than €1.5 billion in the last financial year. Additionally, the obligation for companies to adopt a climate change transition plan in the CSDDD was removed from the final Omnibus text.
    • A VSME, or voluntary standard for small and medium-sized enterprises, has been developed by EFRAG and adopted by the European Commission as a recommendation for companies under the new threshold. The VSME standard helps define the value chain cap or limit of what information companies can require their suppliers to provide.

    What will happen next?

    • The Sustainability Omnibus advocates for the introduction of updated sustainability reporting standards designed to ensure compliance with CSRD. EFRAG, the technical body tasked with the revision and streamlining of the European Sustainability Reporting Standards (ESRS), has published thelatest draft of the updated standards in early December.
    • The revised ESRS have been presented to the European Commission. It is anticipated that these reporting standards will be legally enacted through a delegated act by mid-2026, becoming applicable to financial years commencing on or after 1st January 2027.
    • The amended standards will be shorter and simpler. 61% of the data points have been removed and all voluntary disclosures were eliminated.

    Which additional amendments have been implemented in the legislation?

    • The double materiality assessment (DMA) process has been simplified with a top-down approach recommended. The double materiality principle itself is not modified, and a DMA is still required to comply with CSRD.
    • The Omnibus eliminated the plan for EFRAG to develop standard di settore
    • The European Commission will adoptassicurazione limitata standards by July 2027. The former requirement to move to reasonable assurance over time was removed.

    Modifiche al CSRD nell'ambito del Sustainability Omnibus

    Previous CSRD Scope 

    Sequenza Temporale Post-Omnibus

    Post-Omnibus Scope

    CSRD "First wave"  

    • Subject to NFRD  

    • Listed on an EU-regulated market  

    • With 500 or more employees 

     

    Reporting for 2025 and 2026 will utilize ESRS Set One, prior to the implementation of Omnibus ESRS.

    • Entities within the applicable scope may utilise the 'Quick Fix' provisions to postpone the submission of certain data.

    Relazione del 2027 utilizzando il Simplified ESRS.2027 reporting using the Simplified ESRS.

     

    Enterprises with more than 1,000 employees and a net turnover exceeding €450 million

    CSRD "Second wave"  

    Grandi imprese che sono:Large undertakings that are: 

    • Non incluso nella Prima Ondata

    • Listed or unlisted 

     

    The reporting schedule has been postponed by two years, with reports now expected in 2028 for entities that remain within the scope.

     

    Enterprises with more than 1,000 employees and a net turnover of €450 million

    CSRD "Third wave"  

    • Listed SMEs 

     

    Exempted from mandatory reporting

     

    Firms employing fewer than 1,000 individuals would be exempt, encompassing all small and medium-sized enterprises (SMEs). These entities have the option to voluntarily report using the VSME standard.

    CSRD "Quarta Ondata" 

    • Giornalisti al di fuori dell'UE

     

    Mandato nel 2029 basato sui dati del 2028.2029 on 2028 data.

     

    Enterprises with over €450 million in revenue generated within the EU, which also have at least one subsidiary or branch in the EU with over €200 million in revenue.
    omnibus webinar poll chart

    Nasdaq Poll Results

    Nasdaq surveyed* 436 sustainability professionals from across the US and Europe in varying industries about their CSRD preparedness level and found there was a large range in readiness.

    A majority of poll respondents reported moderate levels of CSRD preparedness:

    • 45% are subject to it in the next two years (assuming nothing changes)

    • 27% are getting prepared and educated but not yet reporting 

    *Poll results captured from attendees of the February 13th, 2025 webinar titled The EU Omnibus: What could it mean for EU Sustainability Regulations?. View the webinar recording here.

    Nasdaq Poll Results

    Nasdaq surveyed* 436 sustainability professionals from across the US and Europe in varying industries about their CSRD preparedness level and found there was a large range in readiness.

    A majority of poll respondents reported moderate levels of CSRD preparedness:

    • 45% are subject to it in the next two years (assuming nothing changes)

    • 27% are getting prepared and educated but not yet reporting 

    *Poll results captured from attendees of the February 13th, 2025 webinar titled The EU Omnibus: What could it mean for EU Sustainability Regulations?. View the webinar recording here.

    Stay Informed

    insight tracker figure 2

    AI-powered CSRD insights Tracker

    Early reporting company insights, powered by Nasdaq Lens™

    Nasdaq Lens conducted an in-depth review of companies that have published annual reports in alignment with CSRD standards. This review highlights key insights such as trends in double materiality, variations in reporting formats, and the comprehensiveness of disclosures. These factors are crucial to consider in the context of the evolving CSRD framework and ongoing EU regulatory dialogues concerning global competitiveness and the Omnibus initiative.

    Access the tracker ->

    Early reporting company insights, powered by Nasdaq Lens™

    Nasdaq Lens conducted an examination of firms that have published their annual reports in alignment with CSRD standards. The findings highlight trends in double materiality, variations in reporting formats, and the comprehensiveness of disclosures. These insights are crucial in the context of ongoing CSRD developments and discussions within the EU regarding global competitiveness and Omnibus initiatives.

    Access the tracker ->

    Request a Free CSRD Readiness Assessment

    Receive a free evaluation of your CSRD readiness from Nasdaq Lens. This tool leverages generative AI and data from over 9,000 international companies to identify advancements and deficiencies in meeting the European Sustainability Reporting Standards (ESRS).

    Request your free assessment ->

     

     

    1 As of 20th February 2025; The percentage change is calculated using data from 20th February 2025 (current analysis) compared to 7th February 2025 (previous analysis); The analysis targets companies based in the EU; ESRS 2 is not included. 

    Nasdaq Lens employs generative artificial intelligence (AI) to create content. It is important to note that AI can sometimes generate results that are outdated, inaccurate, or misleading. Therefore, clients using Nasdaq Lens must ensure they verify the accuracy of the content produced before utilizing it for any purpose. The output from AI is not designed to provide legal advice or to form an attorney-client or fiduciary relationship. Clients are advised to consult their legal advisors to obtain guidance tailored to their individual situations.

    © 2025 Nasdaq, Inc. The Nasdaq logo and the Nasdaq 'ribbon' logo are the registered and unregistered trademarks, or service marks, of Nasdaq, Inc. in the U.S. and other countries. All rights reserved. This communication and the content found by following any link herein are being provided to you by Nasdaq Sustainability Solutions, a business of Nasdaq, Inc. and certain of its subsidiaries (collectively, "Nasdaq"), for informational purposes only. Nothing herein shall constitute a recommendation, solicitation, invitation, inducement, promotion, or offer for the purchase or sale of any investment product, nor shall this material be construed in any way as investment, legal, or tax advice, or as a recommendation, reference, or endorsement by Nasdaq. Nasdaq makes no representation or warranty with respect to this communication or such content and expressly disclaims any implied warranty under law. At the time of publication, the information herein was believed to be accurate, however, such information is subject to change without notice. This information is not directed or intended for distribution to, or use by, any citizen or resident of, or otherwise located in, any jurisdiction where such distribution or use would be contrary to any law or regulation or which would subject Nasdaq to any registration or licensing requirements or any other liability within such jurisdiction. By reviewing this material, you acknowledge that neither Nasdaq nor any of its third-party providers shall under any circumstance be liable for any lost profits or lost opportunity, direct, indirect, special, consequential, incidental, or punitive damages whatsoever, even if Nasdaq or its third-party providers have been advised of the possibility of such damages. 

    AI Translation

    Our translation tool strives for accuracy, yet no machine translation is flawless or a substitute for human translators. Translations are offered as a convenience, "as is." We do not guarantee the accuracy, reliability, or correctness of translations from English to other languages. Certain content may not translate accurately due to software limitations.

    The original English text prevails on the website. Variances in translation are non-binding and hold no legal weight for compliance or enforcement. For queries about translated content accuracy, consult the official English version of our site.

    Our translation tool strives for accuracy, yet no machine translation is flawless or a substitute for human translators. Translations are offered as a convenience, "as is." We do not guarantee the accuracy, reliability, or correctness of translations from English to other languages. Certain content may not translate accurately due to software limitations.The original English text prevails on the website. Variances in translation are non-binding and hold no legal weight for compliance or enforcement. For queries about translated content accuracy, consult the official English version of our site.
    AI