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Omnibus Directive - simplifying regulations and supporting business

The objective of the Omnibus Package is to streamline legislation, reduce bureaucracy and improve the business environment in the EU. It covers a number of changes relating to ESG reporting and the ESRS standards.

Omnibus Conference - what happened on 26 February 2025?

On that day, the European Commission presented proposals to amend and reduce the regulatory burden under the CSRD Directive. Let us summarise what the new rules look like:

• Double materiality assessment - remains unchanged.
• Scope of reporting - reporting obligation for companies with more than 1,000 employees that also meet the financial thresholds (turnover above EUR 50 million or balance sheet total above EUR 25 million).
• Entry into force of the regulations - postponed by 2 years ("stop the clock").
• Simplification of ESRS standards - reduction in the number of data points, clarification of requirements and alignment with other regulations.
• Voluntary reporting - for companies with fewer than 1,000 employees, based on VSME (EFRAG) and with reduced information requirements in the value chain.
• Sector standards - removal of the requirement.
• Taxonomy - not mandatory for companies with fewer than 1,000 employees, voluntary for companies with more than 1,000 employees and turnover below EUR 450 million.
• Audits - retention of limited assurance, removal of the requirement for reasonable assurance.
• CSDDD - reduction of burdens in supply chains, focus on direct business partners.
• CBAM - simplified treatment of small, occasional imports of CBAM goods below the annual threshold of 50 tonnes. These importers will no longer be subject to any CBAM obligations.
• InvestEU - mobilisation of an additional EUR 50 billion, including for green energy.

The Omnibus will not take effect "tomorrow" - what does this mean for companies?

Ever since the publication of the changes envisaged under the Omnibus Directive, the media has been flooded with misleading messages, including headlines suggesting that Omnibus means "the end of ESG". What is the reality?

The changes concerning ESG reporting for 2025 are unlikely to be adopted that quickly. Public consultations still have to take place, followed by a lengthy dialogue between EU legislative bodies, which will be responsible for implementing the Omnibus Directive into Polish law.

The European Commission and other EU institutions may not manage to adopt the amendments by the end of the year, and even if they do, national legislation, in particular the Polish Accounting Act, will also need to be adjusted, which will further prolong the process.

Assuming that the rules will enter into force on time is risky - the legislative process is complex and multi stage. At the same time, preparing a report in line with the ESRS takes time, which is why companies reporting for 2024 and 2025 should continue their work in accordance with the current requirements instead of waiting for potential changes. Failure to submit a report may result in various sanctions.

The Omnibus has reduced CSRD requirements - what next?

Although the Omnibus Package has lowered reporting obligations, instead of putting their activities on hold, businesses should reflect on and plan their next steps. What is worth considering now?

• Monitoring further developments - the consultation process is still ongoing, so for now it is not advisable to change strategy.
• Impact on financing and relations with banks - it is worth analysing whether financial institutions and other stakeholders will continue to require ESG reports.
• Access to EU funds for the green transition - EU budget resources earmarked for the green transition will be available to companies reporting under the Taxonomy, which forms part of sustainability reporting.
• Identification of risks and opportunities - regulatory changes are also an opportunity to reconsider strategy and potential competitive advantages.
• Communication and marketing - a transparent approach to ESG can be an important element in building brand image and value.
• Expectations in the supply chain - despite legal changes, business partners may continue to require reporting, in particular larger entities subject to the CSRD.

Does reporting still make sense? Even if regulations are delayed, companies may still be required to report, and a well prepared ESG strategy can deliver long term benefits. Rather than waiting, it is worth preparing for different scenarios and using this time for strategic planning.

Why is ESG reporting still worthwhile?

The CSRD is not the only reason to report on ESG. Companies will continue to provide information for the needs of supply chains, business partners and financial institutions. Banks are increasingly linking more favourable financing conditions to the quality of ESG data, and business partners expect transparency on sustainability issues.

Monitoring changes and taking a proactive approach to ESG will help companies to prepare better for future regulations and strengthen their position on the market.

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