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The European omnibus debate in the home stretch
As part of the European Green Deal — now known as the «Clean Industrial Deal» — the guidelines on sustainability reporting are being revised. The focus is on the Omnibus Package I, which includes the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), as well as on the Omnibus Package II, which aims to promote investment in green technologies.
Key dates:
- February 26, 2025: Publication of the Omnibus Packages by the EU Commission
- April 14, 2025: Formal adoption of Omnibus I “Stop the clock” – deadline extension for CSRD/CSDDD
- October 22, 2025: Rejection of direct trilogue negotiations between the EU Council, EU Parliament, and EU Commission on Omnibus Packages I and II
- November 13, 2025: New plenary vote in the EU Parliament – if adopted, trilogue negotiations will follow with the aim of finalizing the legislation by the end of 2025
Key points:
CSRD: Planned changes
- Thresholds:
- 1,000 employees and >€450 million in revenue or >€25 million in total assets
- First wave: Depending on national implementation, CSRD reporting requirements remain in place. Exception: In Germany, for example, CSRD has not been transposed into national law, so the Non-Financial Reporting Directive (NFRD) continues to apply there.
- Wave 2: Large, unlisted companies with >250 employees will report from 2028 for the 2027 financial year
- Wave 3: Capital market-oriented SMEs will report from 2029 for the 2028 financial year
CSDDD: Planned changes
- Thresholds:
- Revenue > EUR 1.5 billion and 5,000 employees
- Due diligence obligations:
- Focus on direct business partners
- Indirect partners only to be checked if there are objective indications
- Obligation to provide information to partners only for companies with >1,000 employees
- Liability and sanctions:
- Financial sanctions remain in place
- Liability issues are governed by national law
- Postponement of initial application: Mandatory application only for the 2028 financial year
Outlook
It remains uncertain whether the Omnibus Packages will be adopted by the end of 2025 or whether the thresholds will change again. We hope to have more information after November 13. One thing is clear: companies in the second and third waves are gaining time and should use it to prepare for CSRD and CSDDD.
In spring 2026, the Swiss Federal Council will decide how sustainability reporting should look in Switzerland. However, it is expected that Switzerland will align with European regulations.
What we offer
We support you in navigating this complex regulatory landscape and adapting your non-financial and integrated reporting in a timely manner. Together with you, we identify relevant areas of action and deadlines.
Contact us for an initial consultation: mail@petranix.com
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