Last month, the EU Parliament and Council approved their pending Omnibus deal. The finalized version mirrors the early December proposal and marks the end of the “simplification” process. Ultimately, the Omnibus agreement substantially narrowed the scope of companies subject to the Corporate Sustainability Reporting Directive (CSRD) and reduced the overall number of required datapoints. One interesting note is that wave one companies formerly in scope under the CSRD are not immediately off the hook. As a recent Linklater’s memo notes, such companies will still be required to file reports in 2026:
“Undertakings which are already reporting under the CSRD regime (‘wave one’ undertakings) which would fall out of scope on the basis of these revised tests will need to continue reporting until the financial year starting on or after 1 January 2027 unless the relevant Member State opts to exempt them.”
Additionally, the Corporate Sustainability Due Diligence Directive (CSDDD) saw deep revisions. With its transition plan requirement being scrapped altogether. However, the CSRD/CSDDD Omnibus wasn’t the only thing to pass through the Parliament and Council in late December. A pending political agreement on the European Deforestation Regulation (EUDR) was also approved. That deal saw the EUDR delayed by one year, with obligations starting for medium and large operators on December 30, 2026. Though the EU isn’t done reforming ESG legislation yet. Last month also marked the publication of the Environmental Omnibus, which seeks to simplify various EU environmental laws.
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