On 13 November 2025, the European Parliament adopted its negotiating position on the first "Omnibus" package, which includes changes such as reductions in reporting obligations and due diligence requirements for companies.
The European Parliament's position includes significantly narrowing the scope of the Corporate Sustainability Reporting Directive so that it covers only entities with more than 1,750 employees and annual net turnover exceeding €450 million. It also aims to limit the scope of entities subject to the Corporate Sustainability Due Diligence Directive.
The European Parliament and the Council will begin trilogue negotiations on 18 November, with the aim of reaching a political agreement by the end of 2025.
The European Commission published the first "Omnibus" package on 26 February 2025. The package aimed to simplify EU reporting rules relating to the European Green Deal.
What happened?
On 13 November 2025, the European Parliament adopted its negotiating position on the first "Omnibus" package amending the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D). As stated in the press release, the position was approved by the European Parliament with 382 votes in favour, 59% of the votes cast. This was the second attempt to reach agreement in the European Parliament, following the failed vote on 22 October.
The European Parliament's proposal sets out two main areas of simplification for entities subject to European sustainability regulation:
Corporate Sustainability Reporting Directive (CSRD)
The proposal redefines the scope of the CSRD by specifying that only entities with more than 1,750 employees and annual net turnover exceeding €450 million would be required to continue applying the European Sustainability Reporting Standards (ESRS). These entities would also be subject to the same scope for the taxonomy rules.
The table below compares the proposals of the European Parliament, the Council and the European Commission that are subject to trilogue negotiations:
| Current requirements | European Commission's Omnibus proposal of 26 February 2025 | Council's position of 23 June 2025 | European Parliament's position of 13 November 2025 | |
|---|---|---|---|---|
| CSRD scope | Entities or groups exceeding at least two of the following size criteria: 250 employees; €50 million net turnover; €25 million balance sheet total | Entities or groups with more than 1,000 employees and either net turnover above €50 million or a balance sheet total above €25 million | Entities or groups with more than 1,000 employees and net turnover above €450 million | Entities or groups with more than 1,750 employees and net turnover above €450 million |
| SMEs listed on a regulated market | In scope | Out of scope | Out of scope | Out of scope |
| Non-EU entities | EU turnover above €150 million and (1) a "large" or listed SME subsidiary or (2) a branch with turnover above €40 million | EU turnover above €450 million and (1) a "large" subsidiary or (2) a branch with turnover above €50 million | EU turnover above €450 million and (1) a "large" subsidiary or (2) a branch with turnover above €50 million | At least one subsidiary or branch in the EU with net turnover above €450 million |
The European Parliament also proposed exempting entities classified as "financial holding companies" from the CSRD requirements.
The European Parliament expressed support for the adoption of an EU limited assurance standard by October 2026, while the Council did not set a deadline.
The Parliament is also in favour of the European Commission adopting a voluntary reporting standard based on the Voluntary Sustainability Reporting Standard for non-listed micro, small and medium-sized enterprises (VSME) recommendation published in July. This standard would set the maximum level of information that an entity within the scope of the CSRD may request from its value chain partners.
The Parliament also voted in favour of adopting voluntary sector-specific guidance to help entities and auditors carry out materiality assessments.
Corporate Sustainability Due Diligence Directive (CS3D)
Under the Parliament's position, large companies with more than 5,000 employees and annual net turnover exceeding €1.5 billion would have to comply with the CS3D. A non-EU entity would fall within the scope of the CS3D if its annual net turnover in the EU exceeds €1.5 billion.
Under the Parliament's position, entities subject to the CS3D would no longer be required to adopt a climate transition plan.
What happens next?
On 18 November, the European Parliament and the Council will begin trilogue negotiations aimed at reaching a political agreement by the end of 2025. The final text will be put to a vote by both the European Parliament and the Council and is likely to be published in the Official Journal of the EU in the first quarter of 2026.
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