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    EU Omnibus

    On the 16th of December, 2025 the European legislative bodies reached an agreement on the text of the Sustainability Omnibus, ten months after the Omnibus package was first proposed. The agreement aimed to simplify the directives on corporate sustainability reporting (CSRD) and corporate sustainability due diligence (CSDDD). The reporting obligations have been greatly reduced, and the start of disclosures is delayed for many reporters. Explore below for resources and insights on how your company should consider navigating these changes. Nasdaq Sustainability Solutions is your partner; we can equip you with the latest insights and help you navigate these dynamic regulatory changes.

    Key Highlights

    • The Sustainability Omnibus aims to simplify the regulatory landscape for corporates, while continuing to support the objective of the European Green Deal.
    • Scope Reduction: 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 Proposal 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 employees during the financial year. This means that all smaller companies are now removed from the scope of the directive.
    • 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 calls for the release of new sustainability reporting standards that will be used to comply with CSRD. EFRAG, the technical organization responsible for revising and simplifying the European Sustainability Reporting Standards (ESRS), released thelatest draft of the updated standards in early December. 
    • The Amended ESRS have been submitted to the European Commission. These reporting standards are expected to be adopted into law via a delegated act by mid-2026. They will apply to financial years beginning on or after January 1st, 2027.
    • The amended standards will be shorter and simpler. 61% of the data points have been removed and all voluntary disclosures were eliminated.  

    What other changes were made to 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 sector-standards
    • The European Commission will adopt limited assurance standards by July 2027. The former requirement to move to reasonable assurance over time was removed. 

    Changes to CSRD under the Sustainability Omnibus

    Previous CSRD Scope 

    Post-Omnibus Timeline 

    Post-Omnibus Scope

    CSRD “First wave”  

    • Subject to NFRD  

    • Listed in an EU-regulated market  

    • With 500 or more employees 

     

    2025 and 2026 reporting using ESRS Set One (pre-Omnibus ESRS).

    • Undertakings in scope can use the “Quick Fix” provisions to delay reporting some data 

    2027 reporting using the Simplified ESRS.

     

    Undertakings with >1,000 employees  and €450M Net Turnover 

    CSRD “Second wave”  

    Large undertakings that are: 

    • Not included in First Wave   

    • Listed or unlisted 

     

    Two-year delay in current reporting schedule, reports now due in 2028  for undertakings still in scope.

     

    Undertakings with >1,000 employees  and €450M Net Turnover 

    CSRD “Third wave”  

    • Listed SMEs 

     

    Exempted from mandatory reporting

     

    Companies with <1,000 employees would be exempted, which covers all SMEs. These companies can report voluntarily using the VSME standard. 

    CSRD “Fourth Wave” 

    • Non-EU reporters 

     

    Required in 2029 on 2028 data.

     

    Companies with >€450M revenue generated in the EU and at least one EU subsidiary or branch with >€200M 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

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    AI-Powered CSRD Insights Tracker

    Early reporting company insights, powered by Nasdaq Lens™

    Nasdaq Lens analyzed the companies that have released their CSRD-aligned annual reports. Insights from this analysis include double materiality trends, reporting formats, and depth of disclosures, which are important to note amid the CSRD evolution and EU regulatory discussions on global competitiveness and Omnibus efforts. 

    Access the tracker ->

    Early reporting company insights, powered by Nasdaq Lens™

    Nasdaq Lens analyzed the companies that have released their CSRD-aligned annual reports. Insights from this analysis include double materiality trends, reporting formats, and depth of disclosures, which are important to note amid the CSRD evolution and EU regulatory discussions on global competitiveness and Omnibus efforts. 

    Access the tracker ->

    Request a Free CSRD Readiness Assessment

    Get a complimentary CSRD readiness assessment from Nasdaq Lens, which uses generative AI and insights across 9,000+ global companies to highlight progress and gaps at the European Sustainability Reporting Standards (ESRS) overall readiness level.

    Request your free assessment ->

     

     

    1 As of February 20, 2025; The percentage change is based on data from February 20, 2025 (current analysis) versus February 7, 2025 (previous analysis); Analysis is focused on EU-based companies; Excludes ESRS 2 

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