Over the past two months, there have been a number of developments in the omnibus procedure for CSRD (Corporate Sustainability Reporting Directive), ESRS (European Sustainability Reporting Standards) and CSDDD (Corporate Sustainability Due Diligence Directive) – some of which have resulted in final decisions. The changes are intended to reduce bureaucracy, define thresholds more clearly and simplify reporting processes. For many companies, this means immediate relief – at the same time, a relevant group will continue to be subject to reporting requirements. In this article, we summarise what has been decided and what consequences this will have for companies.
Omnibus I: New thresholds and simplified reporting standards
CSRD: Agreement on the new thresholds
On 9 December 2025, the EU agreed on the new thresholds. In addition to the companies in the first wave, all companies with
- more than 1,000 employees and
- a turnover of more than €450 million
report in accordance with CSRD and, accordingly, the EU taxonomy. The regulation applies to both EU companies and companies from third countries with subsidiaries and/or branches in the EU. The new thresholds will take effect as soon as they are transposed into national law, i.e. probably from 2026.
ESRS: Significant simplification of reporting standards intended
There is good news for companies that meet these thresholds: the reporting requirements are to be significantly simplified and given a strong quantitative character. On 3 December 2025, EFRAG submitted the drafts of the revised ESRS to the EU Commission.
The double materiality will remain in place, but will be structured more clearly. The simplifications in data collection are intended to reduce the effort and costs for companies and significantly facilitate the reporting processes. For companies, this is the ideal opportunity to revamp their sustainability report and turn a mandatory exercise into a strategic management tool (see also: Materiality assessment as a strong foundation for a sustainability strategy).
Changes to due diligence obligations (CSDDD)
In future, due diligence obligations will only apply to very large companies with more than 5,000 employees and a turnover of more than 1.5 billion euros.
The rules follow a risk-based approach: companies focus on those areas of the value chain where adverse impacts are most likely to occur. If a company identifies several areas where the negative effects are equally likely or serious, it should prioritise the assessment of impacts that directly affect its direct business partners.
To minimise the effort required by companies, comprehensive mapping exercises of the entire value chain are no longer necessary. A structured scoping analysis is sufficient.
What matters now and how EurA supports you
The trilogue agreement brings more clarity for companies. Those above the thresholds must consistently adapt their processes to the requirements of the CSRD and CSDDD. Companies just below the thresholds should closely monitor developments, as they may also be indirectly affected via supply chains.
In practice, many companies are already facing a common challenge: preparing sustainability data in such a way that it is methodologically consistent, comprehensibly documented and verifiable. Even well-prepared teams get stuck at certain points. (You can find out more about typical pitfalls and valuable lessons from the first CSRD reports here: CSRD – Wave One: Lessons learned, quick fixes and practical tips.)
With our three-step "CSRD Rescue" approach, we precisely close these gaps and make our clients' reports resilient for limited assurance:
- GAP analysis & prioritisation – targeted identification of relevant deviations and priority planning for quick, effective improvements.
- Double materiality analysis – methodical refinement, optimisation as needed and clear documentation.
- Data mapping – ESRS-compliant selection of relevant data points for the report.
- Data collection – support for consistent and methodically clean data collection
- Report draft – clear ESRS-compliant structure with relevant content
Feel free to take advantage of our non-binding initial consultation: Together, we will examine the extent to which your company is affected by the new thresholds, whether essential elements are already fulfilled and where targeted refinements would be useful. This will give you a clear assessment of which next steps are really relevant for reliable preparation for the limited assurance.
Sources and further information
EurA AG
T- 079619256-0Max-Eyth-Straße 2
73479 Ellwangen
info@eura-ag.com