- Bogdana Vatashka
- 26.11.25
- 1 min
- Funding advice, For SME, For research
Your contact person
Olga Schmidt
On 13 November 2025, the EU Parliament adopted its position on the amendment to the directive on the simplification of sustainability reporting (CSRD) and due diligence obligations (CSDDD). Together with the Council's position, which was published on 23 June 2025, this represents the second important negotiating position for the so-called substance proposal.
This article classifies the current developments, summarises the key changes and highlights the implications for companies that are already becoming apparent today.
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What is the Substance Proposal? The Substance Proposal aims to simplify sustainability reporting and due diligence obligations in the EU. It is part of the agenda to reduce bureaucracy and refers to the CSRD (Corporate Sustainability Reporting Directive), EU Taxonomy Regulation and CSDDD (Corporate Sustainability Due Diligence Directive). |
This would further reduce the number of companies directly affected.
Indirect impact remains: Even if numerous companies are no longer directly subject to reporting requirements in future, large companies will continue to demand ESG information from their supply chain. This means that many SMEs will remain indirectly affected by the CSRD and will have to provide sustainability information.
Here, too, the focus is on very large companies, without the associated requirements along the value chains losing any of their significance.
The trilogue negotiations between the European Parliament, the Council and the Commission began on 18 November 2025. The aim is to reach an agreement before the end of 2025.
| Institution | Thresholds for CSRD reporting requirements in 2025 |
| European Commission | >1,000 employees and >€50 million turnover or >€25 million balance sheet total |
| Council of the European Union | >€450 million turnover |
| European Parliament | >1,750 employees and >€450 million turnover |
It remains to be seen how the final thresholds will be set.
For companies, this means that even if the formal scope of application is redefined, internal preparations should not be put on hold. The EU remains clearly focused on sustainability-related transparency and governance.
Recommendation for you: Continue to report in a structured manner – but with clear prioritisation. Materiality, proportionality and efficiency are becoming more important.
(Discover here how you can use the materiality analysis as a strategic tool: Materiality assessment as a strong basis for a sustainability strategy)
For these companies, the core requirements remain unchanged.
It is therefore important to:Even if simplifications are foreseen, the ESRS will remain the basis for reporting.
(Important conclusions from the challenges faced by the first companies reporting under the CSRD can be found here: CSRD – Wave One: Lessons learned, quick fixes and practical tips)
The indirect effects remain. ESG information must continue to be provided, often in standardised, comparable formats, such as the VSME standard – a European reporting standard developed specifically for SMEs.
(Click here to learn more: VSME standard: lean solution for your sustainability report)
With the Parliament's position, the legislative process to simplify sustainability reporting is gaining momentum. The proposed higher thresholds provide relief, but do not change the fundamental direction of European sustainability regulation.
For companies, this means fewer obligations – but still clear expectations in terms of transparency, management and reliability. The coming weeks will show the extent to which Parliament and the Council will agree in the trilogue. One thing is already clear today: proactive, pragmatic sustainability management remains a key success factor.
Do you have any questions or need expert support?
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Your contact person
Olga Schmidt
EurA AG
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