17 mars 2025
Sustainability Omnibus – everything you need to know
On February 26, 2025, the EU Commission proposed a new initiative called Omnibus #1, aimed at easing the burdens of sustainability reporting under CSRD, CSDDD, and the EU Taxonomy.
What does it mean?
Based on Mario Draghi's report "The Future of European Competitiveness" and the Budapest Declaration, which aims to reduce administrative burdens for SMEs, the European Commission has put forward a proposal. This Omnibus proposal, which consolidates and simplifies legislation, will, if implemented, significantly change the number of companies required to report.
New size thresholds
The proposal includes a significant increase in the size thresholds for CSRD, so that the requirements will only apply to companies/groups that have:
- More than 1,000 employees, and
- Either a turnover of more than DKK 391 million (EUR 50 million),
- Or a balance sheet total of more than DKK 196 million (EUR 25 million)
These thresholds apply to both listed and unlisted companies. Listed companies below the new thresholds are also exempt from reporting requirements.
What does it mean for companies?
The new size thresholds mean that many companies, which were supposed to report for the first time in 2025 or 2026, will no longer be subject to reporting requirements. Companies not covered by the future CSRD reporting requirements can still report according to the voluntary VSME standard (Voluntary reporting standard for SMEs (VSME), Concluded | EFRAG).
Postponement of reporting requirements
While the Omnibus proposal is being discussed, the EU Commission proposes to postpone sustainability reporting for companies that were supposed to report for the first time for the financial year 2025 or 2026. The European People's Party (EPP) is pushing for a vote on the proposal to delay sustainability reporting to take place as soon as possible.
Simplifications and changes
The proposal also includes changes to simplify sustainability reporting and due diligence requirements. Additionally, changes to ESRS and an increase in the minimum threshold for reporting and tax payment are proposed. The Commission's detailed proposal is awaited.
What happens next?
Omnibus #1 is still just a proposal and must go through the legislative process in the EU, including discussions and potential amendments by the European Parliament and the Council of the European Union, before it can be realized.
The EU Commission expects this process to be completed by autumn 2026.
What does it mean for you and your company?
If the proposal, published on February 26, is fully implemented, ESG reporting will not cease. Large companies will still need to report across their value chain and thus request data from you and your company.
The proposal will limit large companies' data requests to only what is specified in the VSME standard, which primarily focuses on CO2 emissions, biodiversity, water consumption, and a few data points about the workforce. Our clear recommendation is therefore to continue your efforts despite this proposal.
At Damstahl, we keep you updated on developments. If you have any questions about Omnibus #1 or sustainability reporting in general, feel free to contact us at tro@damstahl.com.
Our Sustainability Team
Thor Rousing
Sustainability Manager
tro@damstahl.com
Lise Marie Møller
CSR & Communication Specialist
lmmo@damstahl.com
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