Understanding the EU Omnibus Package: Don’t Slow Down on CSRD, Strengthen Your Reporting

On February 26, the European Commission unveiled its proposed EU Omnibus Package aimed at providing companies additional time to report, reducing the number of companies in scope, and simplifying a range of EU Green Deal regulations, including the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), the Carbon Border Adjustment (CBAM), and the EU Taxonomy.  

These proposals are not final amendments but represent an initial step in a process that will require approval within each individual EU member state. While the final changes are still being decided, businesses must continue to comply with the existing versions of these regulations. It’s important to note that for companies reporting under CSRD this year (referred to as Wave 1 companies), the requirements remain in effect and must be reported this year.  

For companies set to begin reporting under the existing CSRD timeline starting from 2026 to 2029 (referred to as Wave 2 and beyond), now’s the time to capitalize on the potentially extended compliance timeline. 

Key Proposed Amendments Relating to CSRD

• Scope reduction and reporting timeline delay: The proposed amendments adjust the CSRD thresholds to prioritize larger businesses, make reporting voluntary for smaller ones, and propose a two-year delay for companies in Wave 2 and beyond. A company is deemed to meet the larger businesses threshold when it has over 1,000 employees and either over €50M net turnover or over €25M balance sheet.
• Simplification of reporting standards and assurance requirements: The proposed amendments streamline the CSRD’s technical reporting standards, emphasize quantitative disclosures, and reduce the assurance requirement to limited assurance only. 
• Higher compliance thresholds and simplified reporting for EU Taxonomy to align with key amendments to CSRD: The proposal adjusts the threshold to only large EU companies or corporate groups that must fully comply (those with over €450 million in net turnover). Smaller CSRD-covered firms only need to disclose select financial indicators if they claim alignment and reporting templates are proposed to be reduced significantly. 

While the proposed amendments grant companies additional time to prepare for the EU regulations, they are not an impetus to slow down. Instead, the amendments provide an opportunity to strengthen CSRD readiness by enhancing data quality and improving reporting efficiencies.  

5 Next Steps

See how companies in Wave 2 and beyond are making the most of the EU Omnibus Package through the following five areas: 

1. Perform a dry run: The proposed two-year delay allows companies to pilot their reporting process internally before formal compliance begins. Businesses should maintain their momentum in CSRD preparation by leveraging this additional time to engage with key internal stakeholders, understand gaps in data collection, and establish robust ESG data management systems to conduct effective dry runs. 
2. Focus on high-impact climate disclosures: Identify high-impact quantitative climate disclosures that affect your business and stakeholders to ensure informed internal decision-making when addressing gaps in CSRD compliance. The proposed changes to technical requirements emphasize streamlining qualitative disclosures, while most quantitative climate disclosures will likely remain in scope. Also, the common core of quantitative disclosures around the globe (including California’s Climate Act) are climate disclosures and emissions reporting, so focusing on these disclosures will satisfy numerous reporting requirements. 
3. Strengthen the Double Materiality Assessment (DMA): Because technical reporting requirements are planned to be streamlined while maintaining emphasis on quantitative climate disclosures, companies can use this extra time to re-evaluate impacts, risks, and opportunities across their value chain by strengthening their DMA. This may include refreshing previous conclusions or enhancing documentation.  
4. Improve internal controls and processes: The proposed two-year delay offers companies the opportunity to achieve their ideal ESG data collection future state by providing additional time to design and implement processes and internal controls. Companies should conduct thorough walkthroughs to trace data sources, identify in-scope systems, determine where additional review layers and segregation of duties are needed, and ensure all processes are documented. 
5. Understand the impact of other reporting requirements: Other sustainability reporting standards continue to be released within the EU and globally, such as California’s SB 253 and SB 261 and New York’s SB 3456 and SB 3697. Invest the time upfront to synchronize your overall ESG reporting timelines and roadmaps to ensure you’re consolidating effort and spending time on what matters most. 

Need Help? 

Now’s the time to strengthen your ESG reporting efforts to ensure CSRD readiness. To remain ahead of the ESG curve, contact CrossCountry Consulting for assistance with your sustainability reporting needs.