The Omnibus Package and CSRD: What is your destination now?
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
Introduction
On February 26, 2025, the EU Commission released the Omnibus I package as part of the Competitive Compass for the EU. The Omnibus I package consists of proposals to amend EU Taxonomy, CSRD and CSDDD amongst others.
The Omnibus I package has been introduced as the response to the announcement made by the president of the European Commission, Ursula von der Leyen, at a press conference November 8, 2024, when she indicated that an “omnibus” will be introduced to support the reduction of the reporting burden currently understood to be contained through the EU Taxonomy Regulation (EU Taxonomy), the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
Since then, we have seen the publication of A Competitiveness Compass for the EU on January 29, 2025, and the Commission work programme 2025 on February 11.
The proposed amending legislation can be divided into two:
- Proposal 1 - The Pause button: The first is a Directive introducing a proposal to postpone all reporting requirements for undertakings due to report in 2026 and 2027 (Category 2- and Category 3 reporters) by two years.
- Our expectation: We expect to see this proposed legislation follow the “fast-track” principle, which should mean that we could see a Directive in the next 3-6 months that then needs to be transposed in Ireland for the legislation to take effect.
- Proposal 2 – Proposed amendments: The second is a Directive outlining detailed proposed amendments to CSRD and CSDDD specifically. We provide an outline of the main changes included in the proposals below.
- Our expectation: We do not expect to see this proposed legislation follow the “fast-track” principle. The normal legislative process on average would be a 12–18-month process. Given the priority that has been raised in this regard we do expect it to be prioritised in Parliament and by the Council.
It is important to note that these are proposals only and existing legislation already exist in Member States which transposed CSRD, including in Ireland.
Proposed update to the scope for CSRD reporting
| Category | Existing Legislation | Proposed Changes |
|---|---|---|
|
Category 1
|
FY2024
**designated by national authorities as public-interest entities |
Continue Irrespective of legal structure, an undertaking/group that at the balance sheet date
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:
|
FY2027
Irrespective of legal structure, an undertaking/group that at the balance sheet date
|
|
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:
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
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:
|
FY2028
Non-EU Parent must meet the following criteria:
|
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 and < €450 million net turnover.
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.
Learn more about how our CSRD solutions can help you
Offical publications
Authors
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Janice Daly Janice is a partner in our advisory practice, leading our sustainability offering. Specialising in sustainable finance and climate risk, Janice has over 15 years of global financial markets experience, where she held senior roles across sustainable finance, climate risk, strategic finance and treasury.View Profile -
Louise Kelly Louise has over 14 years’ experience working on all sizes of public sector and privately owned companies. Her portfolio includes clients in various sectors including construction, education, motor retail, manufacturing and public sector.View Profile -
Catherine Duggan Catherine is a senior energy/sustainability specialist with 15 years global experience, who joined Grant Thornton in 2021 to lead the sustainability offering in Financial Services.View Profile -
Joané Dickinson Joané is the Head of Sustainability Technical for Grant Thornton in Ireland and leads our technical support function, specialising in sustainability assurance, sustainability reporting and corporate reporting and training.View Profile
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