by Jenny Mae Vansteenlandt and Anneleen Wydooghe
On February 25, 2025, the European Commission introduced the Omnibus Simplification Package. This legislative proposal aims to simplify the existing sustainability reporting framework (ESG). Its impact is primarily felt within the Corporate Sustainability Reporting Directive (CSRD) and has direct consequences for how companies must carry out their reporting.
Corporate Sustainability Reporting Directive (CSRD): Certain companies are required to report annually on their policies, strategy, risk management, KPIs, and objectives related to ESG factors (environment, social & governance).
Corporate Sustainability Due Diligence Directive (CSDDD): Certain companies must conduct due diligence to identify, prevent, mitigate, and ultimately eliminate harmful impacts within their operations and value chains.
EU Taxonomy: Certain companies must classify their economic activities as sustainable according to specific criteria.
Carbon Border Adjustment Mechanism (CBAM): Importers of certain goods (such as iron, steel, and cement) must report the amount of CO2 emitted during the production of these goods.
Companies must exceed at least two of the following three criteria for two consecutive years:
250 employees
€50 million turnover
€25 million balance sheet total
Companies that met these criteria were initially required to report by 2026 on the 2025 financial year.
Companies currently subject to the CSRD will receive a two-year deferral. This change was approved in April and is expected to be transposed into national law by the end of 2025.
The threshold of 250 employees would be raised to 1,000 employees, combined with either a turnover of €50 million or a balance sheet total of €25 million.
The reporting standards (European Sustainability Reporting Standards or ESRS) contain many complex data points. These will be reduced, clarified, and better aligned with existing legislation.
This part of the proposal still needs to be negotiated substantively within European legislative bodies and among member states. Final decisions may follow in 2025 or 2026, depending on the negotiation progress.
For now, the current criteria above still apply. Companies exceeding two of the three criteria for two consecutive years are subject to the CSRD. Preparation remains essential.
Continue focusing on CSRD implementation. The deferral provides breathing room to initially concentrate on strategic priorities and high-quality reporting.
Finalize the double materiality analysis and anticipate questions from stakeholders (customers, financial institutions, and others). Voluntary standards such as those for SMEs (VSME) can be supplemented with relevant data points from the ESRS.
Even if you may not be CSRD-subject, you could receive inquiries from customers, financial institutions, or other parties regarding your reporting. This is the so-called trickle-down effect. To anticipate these questions, you can use the VSME framework (a reporting standard tailored for SMEs) to prepare a targeted and accessible report.
Although the Omnibus package provides temporary relief, now is the time for companies to strategically invest in sustainable ESG reporting. The transition to simplified reporting under the CSRD is an opportunity to operate in a future-proof and transparent way.
Want to learn more about how to prepare your organization for these changes? Contact our ESG experts for tailored guidance on analyzing impacts, risks, and opportunities.
Want to know more about the Omnibus? Read more on the website of the European Commission
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Jenny Mae Vansteenlandt
Anneleen Wydooghe
Team Manager Sustainability anneleen.wydooghe@vdl.be
Disclaimer
In our opinions, we rely on current legislation, interpretations and legal doctrine. This does not prevent the administration from disputing them or from changing existing interpretations.
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