On 12 February 2025, the European Commission published its new Work Programme setting out a list of the main policy and legislative initiatives it is planning for 2025.
Not surprisingly, this year’s Work Programme is heavily focused on simplification – with 11 out of the 18 legislative initiatives in the WP aimed at simplification (not limited to just sustainability aspects). The Commission is aiming to cut the administrative burden across the board by at least 25% for all companies and by at least 35% for SMEs.
The following is a list of the key EU initiatives that are the most relevant to ESG and sustainability – these are set out in Annexes to the Work Programme.
We will be updating this tracker as and when there are new developments.
| EU INITIATIVE | STATUS | MORE INFORMATION
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First Omnibus package on sustainability simplification (legislative) | Expected in Q1 – possibly on 26 February - although this might be delayed | The first Omnibus package will cover the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD / CS3D), and the Taxonomy Regulation. This is confirmed in the Communication on Implementation and Simplification: “This proposal will cover a far-reaching simplification in the fields of sustainable finance reporting, sustainability due diligence and taxonomy. It will ensure better alignment of the requirements with the needs of investors, proportionate timelines, financial metrics that do not discourage investments in smaller companies in transition, and obligations proportionate to the scale of activities of different companies. It will notably address the trickle-down effect to prevent smaller companies along the supply chains from being subjected in practice to excessive reporting requests that were never intended by the legislators. The carbon border adjustment mechanism requirements will be eased to the benefit of smaller importers, specifically for SMEs and authorities.” There has been a great deal of speculation in the press and on LinkedIn recently about the extent of the changes the Commission is planning to make to the CSRD and CSDDD but the Commission has not yet confirmed this. The Commission has said that it is also preparing a simplification of the Carbon Border Adjustment Mechanism (CBAM) for smaller market players. Our understanding is that the CBAM will be included in the first Omnibus package and will likely include a provision around the de minimis thresholds and provisions for additional downstream products. Linklaters - EU Competitiveness Compass: key sustainability issues Linklaters - EU: Platform on Sustainable Finance details proposals for simplification of the EU taxonomy FT (subscription required) - Brussels to exempt most EU companies from carbon border tax Responsible Investor (subscription required) - EU Omnibus: Commission expected to heavily water down CSRD, CSDDD |
Second Omnibus package on investment simplification (legislative)
| Expected in Q1 | This simplification package is intended to facilitate the implementation of the InvestEU programme and the European Fund for strategic investments, including by simplifying reporting and boosting investment. |
Clean Industrial Deal (non-legislative) | Expected in Q1 – possibly on 26 February
| In the Competitiveness Compass, the Commission said this will set out a “competitiveness-driven approach to decarbonisation” to make the EU an attractive location for manufacturing (including for energy intensive industries) and promoting clean tech and new circular business models. Linklaters - EU Competitiveness Compass: key sustainability issues |
Amendment to EU Climate Law (legislative)
| Expected in Q1 | The Commission is expected to propose a 90% reduction in greenhouse gas emissions by 2040 (from 1990 levels). The EU will also need to agree a 2035 target as part of the Nationally Determined Contribution (NDC) it is required to submit under the Paris Agreement. This will need to be done before the start of COP30 in Brazil in November/December 2025. The current EU target is a 55% reduction by 2030 and net zero by 2050. |
Water Resilience Strategy (non-legislative)
| Expected in Q2 | |
Third Omnibus package, including small mid-caps and removal of paper requirements (legislative)
| Expected in Q2 | The Commission will propose a new definition of small mid-caps for companies that are bigger than SMEs but smaller than large companies, to ensure more proportionate regulation that is adapted to companies’ size. Linklaters - EU Competitiveness Compass: key sustainability issues
|
Sustainable Transport Investment Plan (non-legislative)
| Expected in Q3 | |
Revision of Sustainable Finance Disclosure Regulation (SFDR) (legislative)
| Expected in Q4 | Linklaters - EU: Platform on Sustainable Finance sets out recommendations to Commission for categorisation of products under the SFDR |
Industrial Decarbonisation Accelerator Act (legislative) | Expected in Q4
| In the Competitiveness Compass, the Commission said it aims to extend accelerated permitting to more sectors (e.g. energy intensive sectors) in transition and that Europe must invest more in modernising and expanding its network of energy transmission and distribution infrastructure, accelerating investment in electricity, hydrogen and carbon dioxide transport networks as well as storage systems. The Commission is also planning to publish action plans for energy intensive sectors, such as steel, metals, and chemicals – which it says are the backbone of the European manufacturing system but which are the most vulnerable in this phase of the transition. Linklaters - EU Competitiveness Compass: key sustainability issues |
Revision of REACH Regulation (legislative)
| Expected in Q4
| In the Work Programme Communication, the Commission says that this initiative will provide a simpler regime for the registration, evaluation and authorisation of chemicals and clarity on forever chemicals. The targeted revision of the EU’s rules on chemicals (the REACH Regulation) is intended to contribute to simplifying rules for the chemicals industry without compromising on safety and environmental protection.
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Green Claims Directive (legislative) | Draft Directive is being negotiated by the European Parliament and Council – trilogues started in January 2025 Final agreement is expected before the end of 2025 | Linklaters - EU Parliament adopts first reading position on the Green Claims Directive Linklaters - EU: Council adopts negotiating position on the Green Claims Directive Linklaters - How should companies prepare for the EU’s Green Claims Directive?
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Communication on Implementation and Simplification
The Commission has published a separate Communication on Implementation and Simplification, alongside the Work Programme. (This is separate from the Work Programme Communication.)
The Communication sets out the overall vision for how the Commission intends to deliver unprecedented simplification:
“We will simplify existing rules wherever necessary and ensure that they are better implemented… In 2025, the Commission has made simplification, reducing the reporting burden, cutting red tape, streamlining the process for obtaining permits and simplifying legislation top priorities for the next five years. Every Commissioner will pursue these goals in their areas of responsibility, coordinated by the Commissioner for Implementation and Simplification [Valdis Dombrovskis].”
The first three Omnibus packages set out in the Work Programme will be the first deliverables of this new simplification mandate. But the initial package of Omnibuses is just the start – there may be more Omnibuses and there will definitely be more simplification even if not in an Omnibus format. The goal is to stress-test all existing EU legislation (the EU acquis). Each Commissioner will ensure the stress-testing of the legislation within their areas of responsibility. The Commission will be publishing annual progress reports on this.
In particular, the Commission plans to work more closely with Member States to avoid unlawful “gold plating” when EU law is implemented into national law, including using infringement procedures where necessary. The Commission will also hold at least two implementation dialogues a year with stakeholders, such as industry.
The Commission also intends to carry out “reality checks” with companies to understand their experience on the ground and identify what is (or is not) working. The outcome of these reality checks will feed into the stress testing of existing EU legislation and the design of future simplification proposals.
The Communication states that the aim is to simplify the EU regulatory framework without undermining policy goals and high standards. With that in mind, the Commission is inviting the European Parliament and Council to fast-track the first series of Omnibus packages set out in the Work Programme, without reopening other parts of the legislation. However, all the Commission can do is “invite” the EP and Council to do this – once the legislative process has started, the Commission will have little control over whether the co-legislators decide to propose other changes to the legislation.
Both this Communication and the Work Programme should be read alongside the Commission’s Competitiveness Compass which was published on 29 January 2025 and is intended to guide the Commission’s work in the coming five years with the aim of boosting EU competitiveness (see our previous blog post).
Further reading
For more information on the new Commission’s general direction of travel on sustainability matters, see our previous blog posts:
- What does the new European Commission have in store for sustainability?
- EU Omnibus Regulation: what do we know so far?
- EU Competitiveness Compass: key sustainability issues
- EU Tracker 2024: Which ESG proposals have been adopted and which are still outstanding?
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