Omnibus update: What currently applies – and what changes are planned

Since the publication of the EU Commission's omnibus proposal on February 26, 2025, there have been significant developments in sustainability reporting. This article provides a structured overview of the current status in order to clarify the most common misunderstandings.

Structure of omnibus proposals

The omnibus proposal consists of two parts:

Omnibus I includes regulatory changes in sustainability reporting:

• Proposal 80: Postponement of CSRD and CSDDD deadlines, also referred to as “stop-the-clock”
• Proposal 81: Adjustments to thresholds and requirements under CSRD, the EU Taxonomy, and CSDDD
• Proposal 87: Changes to thresholds and requirements under CBAM

More information on proposals 81 and 87 can be found here.

Omnibus II  relates to the simplification of European investment programmes:

• Proposal 84: Revision of the existing InvestEU funding

You can find more details about this proposal here.

Decision on “stop-the-clock” (proposal 80)

On April 3, 2025, the European Parliament approved Proposal 80 in a fast-track procedure, and EU Directive 2025/794 came into force on April 17, 2025. The member states are now obliged to transpose the directive into national law by December 31, 2025 at the latest in order to ensure legal certainty for companies.

That means:

• For large, capital market-oriented companies already subject to the Non-Financial Reporting Directive (NFRD), nothing changes. These companies must continue to report in accordance with the CSRD for fiscal year 2024. In Germany and several other countries, the NFRD still applies to fiscal year 2024 due to the absence of a CSRD transposition law – and the CSRD is expected to apply from fiscal year 2025, provided a national law is in place by then.
• For all other companies, the start of the CSRD reporting obligation will be postponed by two years. The earliest reporting period will therefore be fiscal year 2027.
• The Corporate Sustainability Due Diligence Directive (CSDDD) will also be delayed by one year. National implementation is scheduled for mid-2027, with reporting requirements starting from July 2028.

Here is the official press release from the European Parliament.

These further steps regarding the omnibus proposal are already known

1. Changes to ESRS data points

The European Financial Reporting Advisory Group (EFRAG) has now been officially mandated by the EU Commission to revise the existing ESRS data points by October 2025. The aim is to reduce reporting burdens and place greater emphasis on quantitative information. In addition, the share of voluntary data points is to be increased. However, the extent of the planned reduction is not yet known.

For the EU Taxonomy, a reduction of around 70 percent in reportable data points is foreseen – though this applies only to a subset of all ESRS disclosures.

A public consultation on the revision of ESRS Set 1 is currently open until May 6, 2025. Feedback can be submitted via this link.

The consultation questionnaire is structured around five main topics:

1. Materiality
2. Narrative disclosures
3. Quantitative disclosures and references to other EU regulations
4. Simplification of the standards in terms of structure, presentation, and interoperability
5. Other comments or suggestions

When responding to the consultation, it is recommended to follow the questionnaire structure, refer to specific parts of ESRS Set 1, briefly explain the issue, provide practical examples, and – if possible – offer concrete suggestions for improvement.

The EU Commission plans to enable voluntary application of the revised ESRS for fiscal year 2026, with mandatory application starting from fiscal year 2027.

2. Changes to VSME-related data points

Companies that may no longer fall under the CSRD due to the likely introduction of a new threshold based on employee count will be able to report voluntarily under a new standard based on the VSME framework. The so-called value-chain-cap from Omnibus Proposal 81 aims to ensure that suppliers of CSRD-reporting companies are not asked to provide more information than required by the voluntary standard.

However, this new voluntary standard has not yet been defined. It is to be based on the VSME, which was finalized in December 2024 and originally designed for non-listed companies with up to 250 employees. Accordingly, the VSME must be adapted for broader application. The new standard is to be published four months after the adoption of Proposal 81, though no specific date has been announced yet.

3. Parliamentary timeline for further changes

Discussions on the more complex Proposals 81 and 87 have just begun in the European Parliament and the Council. According to insiders, a vote in the Parliament’s lead Legal Affairs Committee (JURI) is planned for October 13, 2025. A final agreement between all three EU institutions is therefore not expected before Q4 2025.

Further insights into the timeline can be found in these LinkedIn posts:
Post by Richard Gardiner
Post by Andreas Rasche

4. Extension of CBAM scope

The EU Commission is currently conducting a consultation with selected stakeholders, such as VDMA, on a possible extension of the CBAM to cover additional product groups and services. Feedback on the survey “Study on the CBAM scope extension to other goods and transportation services” can be submitted until May 5, 2025.

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