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On 26 February, the European Commission introduced the “Omnibus” package, a set of proposed revisions that could bring major updates to key EU regulations on sustainability reporting, corporate due diligence, and trade [1]. If adopted, these changes could reshape compliance obligations and business practices across multiple sectors. While the proposals are still at an early stage, companies operating within the EU should start preparing for the potential regulatory shifts that lie ahead.

What is The EU Omnibus?

"(《世界人权宣言》) EU Omnibus Package is a set of proposed regulatory amendments introduced by the European Commission to refine and adjust key legislative frameworks governing sustainability reporting, corporate due diligence, and trade. Rather than introducing entirely new laws, this package consolidates and modifies existing rules to improve clarity, streamline compliance processes, and address practical challenges faced by businesses. By revisiting certain requirements, the EU aims to ensure that regulations remain effective, proportionate, and aligned with the evolving economic and geopolitical landscape.

Why the EU Omnibus Package Matters

The EU’s regulatory landscape is evolving rapidly, and businesses are struggling to keep pace with mounting compliance demands. The Omnibus package is a response to growing concerns about the complexity and administrative burden of existing sustainability, due diligence, and trade regulations. Instead of merely tightening rules, the proposed amendments aim to strike a balance—ensuring corporate accountability while giving businesses more time and clarity to adapt.

Several factors have driven the need for these changes:

• Regulatory Fatigue – Many companies, especially SMEs, have found it challenging to meet new reporting obligations under frameworks like the 企业可持续发展报告指令 (CSRD). The Omnibus package seeks to ease this burden without compromising transparency.

• Global Market Pressures – Trade disruptions, geopolitical tensions, and shifting supply chain dependencies have made compliance more difficult. The EU is adapting its approach to ensure businesses remain competitive while meeting sustainability goals.

• Economic Realities – Rising costs in energy, materials, and operations mean businesses must allocate resources efficiently. Regulatory adjustments could provide breathing room for companies to integrate sustainability without overwhelming their budgets.

By introducing these revisions, the EU aims to refine—not replace—its existing directives. The Omnibus package is designed to enhance efficiency, simplify compliance, and provide businesses with a more realistic path toward meeting regulatory expectations.

Key Changes Proposed in the EU Omnibus Package

The Omnibus Package introduces targeted adjustments across four major regulatory frameworks. These changes aim to reduce administrative complexity, provide flexibility for businesses, and ensure a more practical approach to compliance. Below are the key proposed revisions:

1. Refinements to the Corporate Sustainability Reporting Directive (CSRD)

The Corporate Sustainability Reporting Directive (CSRD) now applies only to large companies with over 1,000 employees and either €50 million in revenue or a €25 million balance sheet total. Businesses no longer need to collect data from non-CSRD entities, reducing reporting complexity.

Reporting deadlines have been extended by two years for companies that have not yet started implementation, including listed SMEs. The requirement for reasonable assurance has been removed, leaving only limited assurance. Additionally, revisions to the 欧洲可持续发展报告标准 (ESRS) will reduce mandatory disclosures.

Sector-specific reporting requirements have been eliminated, as the EU Commission can no longer introduce them. Companies under 1,000 employees are now exempt but can voluntarily report using a new standard designed for SMEs and very small enterprises (VSMEs).

2. Adjustments to the Corporate Sustainability Due Diligence Directive (CSDDD)

To address concerns over feasibility and administrative burden, the Omnibus Package introduces several modifications to corporate due diligence rules. More time is given for compliance, with the deadline for EU countries to implement the directive extended to July 2027 and due diligence requirements for large companies starting in July 2028. The scope of supply chain oversight is also more focused, limiting due diligence obligations to cases where concrete evidence of potential violations exists. Additionally, reporting frequency has been reduced, requiring assessments every five years instead of annually.

The package also limits data demands on SMEs, preventing large companies from imposing excessive sustainability data requests unless they align with voluntary CSRD reporting standards. Changes to liability rules have been made as well, abandoning the original plan for EU-wide civil liability and allowing each EU country to set its own legal framework for corporate responsibility. Meanwhile, mandatory climate transition plans remain in place, ensuring companies align their strategies with CSRD reporting standards despite other relaxed requirements.

Further adjustments focus on ensuring consistent enforcement across the EU, with additional harmonization efforts to apply due diligence rules uniformly across member states. Notably, the financial sector has been exempted from due diligence obligations, as the EU has removed previous considerations of extending these requirements to financial institutions.

3. Simplifications in the EU Taxonomy Regulation

The Omnibus Package introduces key updates to the 欧盟分类法 framework to enhance sustainability disclosures:

• SME Exemption & Optional Reporting – SMEs are exempt from EU Taxonomy reporting, while large firms can opt out but may disclose voluntarily.

• Recognition for Transitioning Companies – Firms that have started adopting sustainable practices can voluntarily report progress, even if they don’t fully meet Taxonomy criteria.

• Streamlined & Standardized Reporting – The EU Commission will introduce clearer, uniform reporting templates and cut required data points by nearly 70% to reduce compliance burdens.

• Flexible Financial Reporting for Banks – Banks will have more flexibility in applying the Green Asset Ratio (GAR), particularly when dealing with firms outside CSRD scope.

4. Adjustments to the Carbon Border Adjustment Mechanism (CBAM)

As the EU refines its carbon pricing and trade policies, the Omnibus Package proposes adjustments to CBAM [2] to enhance compliance practicality. One key change is the exemption for small-scale importers, allowing businesses that import less than 50 tonnes of CBAM-covered goods per year to be free from reporting obligations, easing the burden on SMEs.

Additionally, the EU is streamlining compliance by simplifying emissions calculations, reporting, and financial accountability, reducing administrative complexity for importers. To strengthen enforcement, anti-abuse measures will be tightened to prevent companies from circumventing CBAM obligations, with national authorities playing a greater role in oversight.

What Remains Unchanged?

While the EU Omnibus Package introduces significant revisions to corporate sustainability regulations, several fundamental principles remain intact. Understanding these unaltered aspects is crucial for businesses as they navigate compliance requirements. Many countries have already transposed the CSRD into national law, and those regulations will continue to be enforced, regardless of ongoing discussions.

Here are two key elements that remain unchanged:

1. Double Materiality: A Core Principle of Sustainability Reporting

的概念 双重物质性 remains a cornerstone of the CSRD. Companies must continue assessing sustainability issues from two perspectives:

• 財務重要性 – How sustainability risks and opportunities impact a company’s financial performance.

• Impact materiality – How a company’s activities affect the environment, society, and stakeholders.

This ensures that businesses do not just report on risks to their bottom line but also on their broader responsibilities in driving sustainable change. Companies must maintain robust frameworks to assess and disclose material sustainability risks and impacts comprehensively.

2. Stakeholder Engagement Remains Essential

Despite regulatory adjustments, the CSRD maintains a strong focus on stakeholder engagement as a critical element of sustainability reporting. Businesses must continue integrating input from various stakeholders—including investors, employees, suppliers, and regulators—when shaping their sustainability strategies and disclosures.

Engagement with stakeholders is essential for:

• Identifying key sustainability risks and opportunities relevant to business operations.

• Ensuring that sustainability reporting aligns with market expectations and regulatory requirements.

• Enhancing transparency and trust in corporate sustainability initiatives.

As the final CSRD regulations take shape across different national legislations, companies must remain proactive in building structured engagement processes and maintaining clear communication with stakeholders. This will not only support compliance but also reinforce long-term business resilience in an evolving regulatory landscape.

Implications for Businesses

The proposed changes in the EU Omnibus Package introduce both challenges and opportunities for businesses. While some requirements have been eased—such as higher reporting thresholds and postponed deadlines—companies must still ensure compliance with the core principles of sustainability reporting. The adjustments provide businesses with more time and flexibility, but they also demand strategic planning to align with evolving regulatory expectations.

Compliance Preparation: Staying Ahead of Regulatory Changes

Even with postponed reporting deadlines and reduced data collection obligations, businesses should not delay their compliance efforts. Companies that have already started implementing the CSRD must continue enhancing their internal reporting systems, while those newly exempt from reporting may still benefit from voluntary sustainability disclosures to maintain investor confidence and market credibility.

Key actions businesses should take:

• Review existing reporting frameworks and align them with the revised CSRD and EU Taxonomy updates.

• Streamline data collection processes to ensure accurate sustainability reporting without excessive administrative burdens.

• Monitor national-level implementations of CSRD and CSDDD, as transposition into local laws may introduce country-specific nuances.

Strategic Adjustments: Rethinking Sustainability Approaches

With fewer mandatory data points and a shift toward simplified sustainability reporting, businesses have an opportunity to refocus on material ESG factors that align with their long-term strategies. The removal of sector-specific reporting standards and the voluntary reporting option for smaller businesses mean that companies can now be more selective in the data they disclose.

How companies should respond:

• Prioritize high-impact sustainability topics that align with business objectives rather than reporting for the sake of compliance.

• Leverage voluntary sustainability reporting to showcase ESG performance and maintain transparency with investors and stakeholders.

• Use the extra time to develop better sustainability strategies, ensuring compliance readiness when future regulatory updates take effect.

Managing Risks and Identifying Opportunities

Although the Omnibus Package reduces some obligations, businesses must remain vigilant about future regulatory shifts. The EU continues to refine its sustainability framework, meaning additional updates and stricter enforcement could follow. Companies that proactively integrate ESG principles into their core business operations will gain a competitive advantage.

Considerations for businesses:

• Supply chain risk management: Despite the reduced due diligence scope, companies must still monitor their direct suppliers for sustainability risks.

• Financial and reputational impact: Investors and consumers continue to demand strong ESG commitments, so scaling back sustainability efforts could harm brand reputation and investment prospects.

• Leveraging sustainability as a business driver: Companies that continue prioritizing sustainability will be better positioned for future regulatory changes, market expectations, and investor preferences.

最终想法

The EU Omnibus Package eases some compliance burdens but does not signal a retreat from the EU’s broader sustainability goals. Businesses should use this period to strengthen ESG strategies, refine reporting processes, and integrate sustainability into long-term planning rather than delay action.

Regulatory uncertainty remains, and future revisions may reintroduce stricter requirements. Companies that proactively align with ESG principles, enhance data management, and stay ahead of national-level implementations will gain a competitive edge.

Rather than seeing these changes as mere compliance adjustments, businesses should leverage sustainability as a strategic advantage, ensuring resilience in an evolving regulatory landscape.

参考资料:

[1] https://commission.europa.eu/publications/omnibus-i_en

[2] https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en