Article

Omnibus explained: Comparing existing legislation and proposed amendments

By:

Janice Daly,

Louise Kelly,

Catherine Duggan,

Joané Dickinson

28 Feb 20254 min read

Understand the key differences between existing legislation and proposed amendments in the Omnibus update. Stay informed on regulatory changes, CSRD reporting scope, assurance requirements, and EU Taxonomy updates.

Contents

Category	Existing Legislation	Proposed Changes
Category 1	FY2024 Any large company/group listed on an EU regulated market >500 employees. Insurance companies with >500 employees. Credit institutions with >500 employees. **designated by national authorities as public-interest entities	Continue Irrespective of legal structure, an undertaking/group that at the balance sheet date Average number employees > 1000 over the financial year, AND meet either of the following: Net turnover > €50 million; Balance sheet total > €25 million Observation: Category 1 reporters with < 1000 employees will potentially fall out of scope with the proposed change.
Category 2	FY2025 Any large company/group that meets two of the following three criteria for two consecutive financial years: Net turnover > €50 million; Balance sheet total > €25 million; Average of > 250 employees over the financial year	FY2027 Irrespective of legal structure, an undertaking/group that at the balance sheet date Average number employees > 1000 over the financial year, AND meet either of the following: Net turnover > €50 million; Balance sheet total > €25 million
Category 3	FY2026 Small and medium sized companies/groups (SMEs) which are listed on an EU regulated market and must meet two of the three criteria for two consecutive financial years: Net turnover > €15 million; Balance sheet total > €7.5 million; Average of > 50 employees over the financial year Small and non-complex institutions and captive (re)insurers meeting Large company/group criteria.	FY2028 Irrespective of legal structure, an undertaking/group that at the balance sheet date Average number employees > 1000 over the financial year, AND meet either of the following: Net turnover > €50 million; Balance sheet total > €25 million Observation: Category 3 reporters will potentially fall out of scope with the proposed change.
Category 4	FY2028 Non-EU Parent must meet the following criteria: Net turnover of €150 million in the EU for the last two consecutive financial years, AND has one of the following: At least one EU Subsidiary that is large or listed, OR; EU Branch with a net turnover of at least €40 million.	FY2028 Non-EU Parent must meet the following criteria: Net turnover of €450 million in the EU for the last two consecutive financial years, AND has one of the following: At least one large EU Subsidiary with >1000 employees, OR; EU Branch with a net turnover of at least €50 million.

The Omnibus Package and CSRD: What is your destination now?

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Other proposed updates include

Value chain

The proposal includes a limit to information that can be requested from entities that do not meet reporting criteria.

This limit is expected to be based on the Voluntary reporting standards (VSME) as prepared by EFRAG.

We encourage the application of the VSME, for those that expect to no longer fall within the reporting scope, should the proposal be approved in its current format. This will allow a competitive advantage in each value chain.

Single electronic reporting format

The proposal maintains the requirement for those required to report, to do in accordance with the electronic reporting format.

The proposal does explicitly indicate that this requirement will only become effective once the Delegated Regulation in this regard has been adopted.

Assurance requirement

The assurance requirement under the proposal will remain a limited assurance only.

We note that it is proposed that targeted assurance guidelines are proposed for issuance by 2026.

European Sustainability Reporting Standards (ESRS)

The proposal, include the revision of the existing ESRS. The revision of the delegated act that establish the ESRS will aim to reduce the number of data points, clarify unclear provisions, focus on numeric data points, improve consistency with other legislations.

The concept of a double materiality assessment has been maintained.

Sector-specific standards

The proposal includes that no sector-specific standards will be introduced.

EU Taxonomy Regulation

The proposal introduce an “optional” EU Taxonomy Reporting obligation for undertakings/parent undertakings with <1000 employees.

The reporting requirement seems to become mandatory when a claim is made that:

activities are associated with economic activities that qualify as environmentally sustainable or,
economic activities that fulfil only certain requirements.

What comes next?

The proposal will now progress to the Parliament and the Council for review and potential changes.

The final Directives will then have to be incorporated into local legislation.

Our expectation is that the proposed extension of timelines will be approved for transposition at Member State level with urgency, which will then allow the detailed proposed changes to be debated before approval. The estimated timeline could range from a 3 to 6-month period.

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Omnibus explained: Comparing existing legislation and proposed amendments

Proposed update to the scope for CSRD reporting