EU Omnibus Tracker: simplification of sustainability rules

First Omnibus package (Omnibus I)

The Commission published the first Omnibus package (Omnibus I) on 26 February 2025.

The first Omnibus package proposed changes to the: 

• Corporate Sustainability Reporting Directive (CSRD);
• Corporate Sustainability Due Diligence Directive (CSDDD / CS3D);
• Taxonomy; and
• Carbon Border Adjustment Mechanism (CBAM). 

See below for more information on each aspect of the Omnibus I.

The “Stop-the-Clock” Directive forms part of the first Omnibus package.

The “Stop-the-Clock” Directive was published in the Official Journal of the EU on 16 April 2025.

Member States must transpose the Directive into national law by 31 December 2025.

The “Stop-the-Clock" Directive delays: 

• the entry into application of the CSRD requirements for large companies that have not yet started reporting, as well as listed SMEs, by two years; and
• the transposition deadline and the first phase of the application (covering the largest companies) of the CSDDD by one year.

Delay to CSRD:

• "Second wave" companies which were due to report in 2026 (in respect of the 2025 financial year) will now need to report in 2028 (in respect of the 2027 financial year).
• "Third wave" companies which were due to report in 2027 (in respect of the 2026 financial year) will now need to report in 2029 (in respect of the 2028 financial year).
• "First wave" companies which needed to report in 2025 (in respect of the 2024 financial year) are addressed via the "Quick Fix" proposal (see below). 

Delay to CSDDD:

• The deadline for transposition into national law was delayed to 26 July 2027 (instead of 2026).
• The deadline for first wave of companies to start complying was delayed to 26 July 2028 (instead of 2027).
• However, these dates have now been delayed by an additional year under the Omnibus I changes to the CSDDD (see below). 

Linklaters - EU: Omnibus "Stop-the-Clock" Directive published in Official Journal of the EU

Linklaters - EU Stop-the-Clock Directive transposition tracker

Omnibus I: changes to CSRD and CSDDD 

(aka the “Requirements proposal”)

On 26 February 2025, the Commission published the Requirements proposal with substantive changes to the CSRD and CSDDD, as part of the Omnibus I package.

The Parliament and the Council reached political agreement on 9 December 2025. 

The Parliament and Council endorsed that political agreement on 16 December 2025.

The approved text now needs to be published in the Official Journal of the EU before it can enter into force.  

The Requirements proposal (which part of the Omnibus I package) makes substantive changes to the CSRD and CSDDD, including (among others): 

• changes to reduce the number of entities that are covered by these regimes;
• removal of the obligation to produce a transition plan from the CSDDD; and
• delaying the transposition date of the CSDDD to 26 July 2028 and delaying the date by which in-scope entities need to comply with the due diligence requirements in the CSDDD to 26 July 2029.

That proposal has now been approved in final form by the European Parliament and Council. That text must now be published in the Official Journal of the EU before it can come into force. See Linklaters - EU Omnibus I: CSRD and CS3D amendments finalised: what do you need to know?

For more information on previous stages of this proposal, see (in chronological order):

• Linklaters - EU: Commission publishes first Omnibus package with changes to CSRD and CSDDD
• Linklaters - Webinar recording: European Commission publishes first Omnibus package – what we know so far - with a focus on CSRD and CSDDD
• Linklaters - EU: Council agrees its negotiating position on the substantive changes to CSRD and CSDDD
• Linklaters - EU: Parliament JURI Committee approves its negotiating position on Omnibus changes to CSRD and CSDDD
• Linklaters - EU Omnibus I: Parliament agrees its negotiating position on changes to the CSRD and CSDDD
• Linklaters - EU: Omnibus I Requirements Proposal – Parliamentary vote outcome

• Linklaters - EU: Changes to CSRD and CSDDD under Omnibus I: Trilogues have commenced. What are the starting positions of the parties?

• Linklaters - New podcast: next steps on changes to CSRD and CSDDD under EU Omnibus

• Linklaters - EU: Council and Parliament reach political agreement on amendments to CSRD and CSDDD under Omnibus I
• Linklaters - Podcast: next steps on changes to CSRD and CSDDD under EU Omnibus

On 26 February 2025, the Commission published (as part of the first Omnibus package) a call for evidence on amendments to the:

• Taxonomy Disclosures Delegated Act;
• Taxonomy Climate Delegated Act; and
• Taxonomy Environmental Delegated Act. 

The call for evidence closed on 26 March 2025.

The Commission adopted the Delegated Act on 4 July 2025. 

The European Parliament and Council had four months  to formally object to the Delegated Act (the “objection period”) but they could ask for this period to be extended. 

If no objections are raised during the objection period (known as “non-objection”), the Delegated Act will be published in the Official Journal of the EU (OJEU) and will enter into force. 

Neither the European Parliament nor the Council have the power to amend the text of the Delegated Act – the most they can do is veto it (and in doing so, they can ask the Commission to amend the text in whole or part). 

On 6 October 2025, the Parliament requested that the scrutiny period be extended for an additional 2 months – until 5 January 2026  (see meeting of the ECON-ENVI Committee). 

The changes in the Delegated Act are intended to apply from 1 January 2026.

The Commission is in the process of adopting an FAQ on these changes (see draft Commission Notice). The current draft says that, for the financial year 2025 (to be reported in 2026), reporting undertakings can choose between two options:

• they can apply the version of the reporting rules as amended by the Omnibus Delegated Act, which will enter into application as of 1 January 2026; or
• they can apply the version of the reporting rules that were applicable until 31 December 2025.

The draft FAQ states that: 

“This draft Commission Notice has been approved in principle by the European Commission on 17 December 2025 and will be formally adopted in all the official languages of the European Union later, as soon as all language versions are available. The clarifications provided in this draft Commission Notice are relevant to the extent the amending Delegated Regulation (Omnibus Delegated Act) adopted on 4 July 2025 will not have been subject to objections made by the European Parliament or by the Council and will have been published in the Official Journal of the European Union.”

The purpose of the amendments to these existing Taxonomy Delegated Acts is to simplify reporting requirements, most notably by introducing a financial materiality threshold and reducing reported data points by around 70%.

Linklaters - EU: European Commission sets out proposals to simplify Taxonomy Delegated Acts

Linklaters: EU: Commission takes next steps on the path to simplifying Taxonomy Reporting

Draft Commission notice with FAQs on the changes 

CBAM simplification and wider review  

On 26 February 2025, the Commission published a proposal for a Regulation amending the existing CBAM Regulation, as part of the Omnibus I package.

The European Parliament adopted the proposal on 10 September and the Council adopted the proposal on 29 September. 

The Regulation was published in the Official Journal of the EU on 17 October and came  into force on the 20 October 2025. 

The Commission has also launched a consultation on a wider review of the CBAM.  The consultation closed on 26 August 2025. The Commission plans to adopt a proposal for a Regulation in Q4 of 2025.

On 26 February 2026, the Commission proposed a number of changes to the existing CBAM Regulation, including a new de minimis mass threshold of 50 tonnes which would exempt 90% of importers from the CBAM while still covering 99% of CO2 emissions from in-scope CBAM emissions. 

On 18 June 2025, the European Parliament and Council reached political agreement  on this proposal. This now needs to be formally adopted by the Parliament and Council before it is published in the Official Journal of the EU. 

On 2 July 2025, the Commission launched a public consultation and call for evidence on extending the scope of the CBAM to include certain downstream products. The objective is to further reduce the risk of carbon leakage and introduce anti-circumvention measures targeting practices intended to avoid CBAM financial obligations. The consultation closes on 26 August 2025. The Commission plans to adopt a proposal for a Regulation in Q4 of 2025.

Linklaters - EU: Commission proposes changes to Carbon Boarder Adjustment Mechanism (CBAM) as part of first Omnibus package

Linklaters - EU: Political agreement reached on CBAM simplification

Linklaters - EU plans to prevent carbon leakage through extension of the CBAM scope and support for EU exporters

Linklaters: EU CBAM simplification: what has changed for importers?

The Commission asked EFRAG to submit their advice on simplification of the existing ESRS by 31 October 2025, and then extended this deadline to 30 November 2025. 

On 31 July 2025, EFRAG published the revised Exposure Drafts of the ESRS and launched a public consultation that closed on 29 September 2025. 

EFRAG has revised the draft ESRS following the public consultation.  EFRAG delivered their recommendations on the revised ESRs to the Commission on 3 December 2025.  

The Commission will now prepare a Delegated Act revising the existing set of ESRS based on EFRAG’s technical advice and will hold a short public consultation before it adopts that Delegated Act. 

Meanwhile, on 30 July 2025, the Commission adopted a Recommendation on voluntary sustainability reporting for non-listed  SMEs. The VSME Standards will serve as the basis for the future voluntary standard proposed in the Omnibus I package, but certain changes may be required. 

The Commission intends to revise the existing (non-sector specific) ESRS under the CSRD to reduce substantially the number of data points, clarify provisions deemed unclear, and improve consistency with other pieces of legislation. This is part of the Omnibus I package. 

The power in the CSRD for the Commission to adopt sector-specific ESRS has been removed as part of the .   

The Commission has also proposed a value chain cap. This means that companies in scope of the CSRD should not seek sustainability information beyond what is set out in a voluntary reporting standard for companies in their value chains that fall outside the scope of the CSRD. The Commission will develop this standard and adopt it as a delegated act once amendments to the CSRD are finalised.

Linklaters - EU CSRD: Commission mandates EFRAG to simplify ESRS

Linklaters - EU: EFRAG launches public call for feedback on ESRS revision

Linklaters - EU CSRD: EFRAG agrees work plan to revise ESRS

Linklaters - EU: EFRAG delivers progress report to the Commission on simplification of ESRS

Linklaters - EU CSRD: Commission grants EFRAG an additional month to deliver simplified ESRS

Linklaters - European Commission adopts Recommendation on voluntary sustainability reporting for SMEs

Linklaters -  EU CSRD: EFRAG publishes revised ESRS for public consultation

Linklaters - EU CSRD: EFRAG submits revised ESRS to the European Commission

The Commission adopted a “Quick Fix” Delegated Act on 11 July 2025. See press release, Delegated Act, Annex and Summary of Modifications.  

The Delegated Act was published in the Official Journal of the European Union and came into force on 13 November 2025. It applies to “wave one” companies under the CSRD with respect to financial years beginning on or after 1 January 2025.

 According to the current ESRS under the CSRD, “wave one” companies can omit information on, amongst other things, the anticipated financial effects of certain sustainability‑related risks. 

The “quick fix” amendment, which applies from financial year 2025, will allow them to omit that same information for financial years 2025 and 2026. This means wave one companies will not have to report additional information compared to financial year 2024. 

In addition, for financial years 2025 and 2026, wave one companies with more than 750 employees will benefit from most of the same phase‑in provisions that currently apply to companies with up to 750 employees. 

Linklaters - EU CSRD: Commission adopts “Quick-Fix” Delegated Act postponing phased-in reporting requirements for “wave one” companies

Linklaters - EU: “Quick-fix” amendments to the ESRS published in the Official Journal of the EU

April 2025 - Draft Delegated Act 

On 15 April 2025, the Commission published a draft Delegated Act amending the EUDR, alongside updated guidance and FAQs. 

The consultation on the draft Delegated Act closed on 13 May 2025. 

Once the Commission has adopted the Delegated Act, the European Parliament and Council will have two months (which can be extended by a further two months) to formally object to the Delegated Act (the “objection period”). 

If no objections are raised during the objection period (known as “non-objection”), the Delegated Act is published in the Official Journal of the EU (OJEU) and enters into force. 

The Delegated Act can also enter into force before the expiry of that period, if the Parliament and the Council have both informed the Commission that they will not object (known as “early non-objection”). 

Neither the European Parliament nor the Council have the power to amend the text of the Delegated Act – the most they can do is to veto it (in doing so, they can ask the Commission to amend the text in whole or part). 

Next steps: The Commission has not yet adopted that Delegated Act.  

October 2025 - Proposal for other targeted changes  

On 23 September 2025, the Commission wrote to the European Parliament and the Council suggesting an additional one year delay to the application of the EUDR, citing difficulties with the IT system designed to track imports of in-scope commodities - see letter. 

However, on 21 October 2025, the Commission published a proposal with targeted changes to the EUDR which did not include a one year delay. 

On 19 November and 26 November 2025, the Council and the Parliament, respectively, adopted their negotiating positions. 

On 4 December 2025, the Council and the Parliament reached political agreement on this file. 

On 18 December 2025, the Parliament and Council endorsed that political agreement. 

The final text was published in the Official Journal of the EU on 23 December 2025 - see here.  

April 2025 - Draft Delegated Act 

On 15 April 2025, the Commission also published a draft Delegated Act focusing on clarifications and scope adjustments requested by stakeholders. The draft Delegated Act includes targeted fixes to the list of in-scope products in Annex I to the EUDR, in particular on the following:

• Exclusion of relevant products without relevant commodities: The inclusion of “ex” in front of several HS Code entries clarifies that products in Annex I to the EUDR are regulated only if produced using a relevant commodity.
• Exclusion of waste: Waste, as well as second-hand and used products, do not fall within the Regulation's scope.
• Product samples: Samples of products and those used for examination, analysis, and testing are excluded from the Regulation.
• Packing materials: Packing materials and containers placed on the EU market or exported as independent products fall within the EUDR scope, while those supporting other products do not.
• Exclusion of correspondence: Items of correspondence and accessory materials are not covered by the Regulation’s scope.

Linklaters - EU: Commission publishes new guidance and draft Delegated Act to simplify due diligence requirements under Deforestation Regulation

The Commission has not yet adopted that Delegated Act.

October 2025 - Proposal for other targeted changes  

On 21 October 2025, the Commission published a separate proposal with other targeted changes to the EUDR, to reduce regulatory obligations on smaller operators and on the downstream part of the value chain and to help prevent overloading the EUDR IT system, including:

• The EUDR will still enter into force on 30 December 2025 for large and medium sized in-scope companies, but it will only apply to micro and small operators from 30 December 2026 (instead of 30 June 2026).
• There will be a six-month grace period in enforcement for large and medium sized in-scope companies. This means that the competent supervisory authorities will not be required to carry out checks and other measures relating to enforcement until 30 June 2026 for large and medium sized companies and 30 December 2026 for micro and small operators.
• Downstream operators and traders will not be required to submit due diligence statements. Only one submission in the EUDR IT system will be required by the operator first placing the relevant products on the market.
• Micro and small primary operators will only be required to submit one-time simplified due diligence declarations (rather than due diligence statements) into the IT system. 

This proposal was formally adopted by the European Parliament and Council on 18 December.

The final text was published in the Official Journal of the EU on 23 December 2025 - see here.  

Previous coverage (in chronological order):

• Linklaters: EU: Commission publishes proposal with targeted changes to Deforestation Regulation
• Linklaters: EU Council and Parliament adopt their negotiating positions on the revision of the Deforestation Regulation
• Council: EU deforestation law: Council and Parliament reach a deal on targeted revision
• Parliament: Deforestation law: deal with Council to postpone and simplify measures
• Linklaters - EU Parliament and Council endorse political deal on revision of Deforestation Regulation

Revision of Sustainable Finance Disclosure Regulation (SFDR)

The Commission published a call for evidence on 2 May 2025.  The call for evidence closed on 30 May 2025.

 On 20 November 2025, the Commission published a proposal with a set of amendments to the Sustainable Finance Disclosure Regulation (SFDR).  

 Revised SFDR significantly reduces the scope and burden of the current SFDR rules but imposes a number of additional obligations, as the regime is shifting from a disclosure regime to a product categorisation regime. 

Linklaters - EU: European Commission launches Call for Evidence to simplify SFDR

Commission - Commission simplifies transparency rules for sustainable financial products

Linklaters - SFDR 2.0: What you need to know

Linklaters - recording of webinar on SFDR 2.0 proposals 

The Commission published the Omnibus IV package on 21 May 2025. 

On 23 May 2025, the Commission launched a consultation on the part of the Omnibus IV package intended to delay the due diligence requirements under the Batteries Regulation. The consultation closed on 23 July 2025. 

The “Stop the Clock” Regulation delaying the due diligence under the Sustainable Batteries Regulation was published in the Official Journal of the EU on 30 July 2025 and came into force on 31 July 2025.

Other proposals need to be debated and agreed on by the European Parliament and Council under the “ordinary legislative procedure”.

On 24 September, the Council agreed its negotiating position on the SMC Proposal.  

The European Parliament has yet to reach its own negotiating position on the file. 

The Omnibus IV includes (among other things) proposed changes to the Sustainable Batteries Regulation 2023 and the F-gas Regulation 2024, as well as measures aimed at a new category of small mid-cap companies (SMCs). 

In particular, the Commission is proposing to make the following changes to the Sustainable Batteries Regulation and F-gas Regulation:

• Delay the date of application of the due diligence obligations in the Sustainable Batteries Directive by two years, from 18 August 2025 to 18 August 2027.
• Delay the deadline for the Commission to publish guidance on the Sustainable Batteries Regulation, from 18 February 2025 to 26 July 2026 (to align with the deadline for publishing guidance on the Corporate Sustainability Due Diligence Directive).
• Expand the exemption from the due diligence requirements in the Sustainable Batteries Regulation to companies with a net turnover of less than EUR 150 million. At present, companies having a net annual turnover of less than EUR 40 million are exempt from the due diligence requirements.
• Limit F-gas Portal registration under the F-gas Regulation to importers that exceed certain annual F-gas thresholds and exporters of certain products and equipment with highly warming F-gases that are prohibited in the EU and are covered by an export restriction.  

The Commission has also proposed the creation of a new category of SMCs for companies that are larger than SMEs but smaller than large companies. The Omnibus IV package extends to SMCs some of the exemptions that are currently available to SMEs. However, this does not affect the Commission’s proposed changes to the Sustainable Batteries Regulation and the F-gas Regulation or other EU sustainability regimes. 

Linklaters - EU: sustainability elements of the Omnibus IV proposal

Linklaters - EU Regulation delaying due diligence rules for batteries published in the OJEU

Council press release - Simplification: Council agrees positions on digitalisation and common specifications, as well as on small mid-caps, to boost EU competitiveness

The Commission published a Single Market Strategy on 21 May 2025, in which it identified fragmented rules on packaging, labelling and waste as one of the ten most harmful barriers to the free movement of goods and services in the EU. 

The Commission plans to address these issues primarily by making product labels clearer and more accessible and by simplifying extended producer responsibility (EPR) schemes for end-of-life products.

These changes will be made via a Circular Economy Omnibus in Q4 2025 and a Circular Economy Act in Q3 2026. 

Linklaters - EU Single Market Strategy: dealing with fragmented rules on packaging, labelling and waste

Linklaters - European Commission takes steps to advance the circular economy

The Commission published a call for evidence on 22 July 2025. This closed on 10 September 2025. 

n 10 December 2025, the Commission published the Environmental Omnibus containing six legislative proposals to simplify environmental legislation in the areas of industrial emissions, circular economy, environmental assessments and geospatial data. 

The six legislative proposals now need to be negotiated by the European Parliament and Council under the “ordinary legislative procedure”, which under normal circumstances tends to take at least 18 months but in this case may happen more quickly.

 The Commission published the Environmental Omnibus containing six legislative proposals to simplify environmental legislation in the areas of industrial emissions, circular economy, environmental assessments and geospatial data. 

Linklaters - EU: Commission launches call for evidence to inform forthcoming Environmental Omnibus

Linklaters - EU: Commission publishes Environmental Omnibus

According to the Commission 2026 Work Programme, the legislative proposal to simplify energy product legislation will be released in Q2 2026.

The Commission published the Chemicals Omnibus on 8 July 2025 with three draft Regulations. 

The three draft Regulations need to be negotiated and adopted by the European Parliament and Council under the “ordinary legislative procedure”.

On 24 September 2025, Council approved its position on the changes to the CLP Regulation. The Parliament approved these changes on 23 October 2025. The Council gave its final sign off on 17 November 2025. The legislative act will now need to be be published in the Official Journal of the EU before it can come into force.

On 5 November 2025, Council adopted its position on the second part of Omnibus VI. 

This Chemicals Omnibus consists of three legislative proposals:

• Proposal for a Regulation amending certain dates of application in the Classification, Labelling and Packaging of Substances and Mixtures (CLP) Regulation;
• Proposal for a Regulation amending certain requirements in the CLP Regulation, the Cosmetic Products Regulation, and the Fertilising Products Regulation; and
• Proposal for a Regulation to strengthen the governance of the European Chemicals Agency (ECHA).

Linklaters - EU: Commission publishes Chemicals Industry Action Plan and Chemicals Simplification Omnibus

Linklaters - Simplification of EU Chemicals Regulation – Defense Readiness Omnibus and Chemicals Industry Action Plan

The Commission published the Defence Readiness Omnibus on 17 June 2025. 

On 3 November 2025, the Commission also published the Staff Working Document. 

Council approved its negotiating position on 26 November 2025. 

Linklaters - EU: sustainable finance and environmental elements of the Defence Readiness Omnibus

Linklaters - Simplification of EU Chemicals Regulation – Defense Readiness Omnibus and Chemicals Industry Action Plan

Commission press release - Communication from the Commission to the European Parliament and the Council

Council press release - Defence industry: Council agrees position on simplification package to boost Europe’s defence industry and readiness

Recommendations of European Ombudswoman on Omnibus I process following NGO complaint

A formal complaint in respect of the Omnibus I was filed by NGOs with the European Ombudswoman on 18 April 2025. 

The European Ombudswoman announced on 27 November that she has found a number of procedural shortcomings in how the European Commission prepared several legislative proposals that it considered urgent (including Omnibus I). 

In April 2025, a number of NGOs (including ClientEarth) filed a formal complaint with the European Ombudswoman concerning how the European Commission prepared the first Omnibus proposal. 

On 27 November 2025, the European Ombudswoman published her conclusions, in which she stated that she had found a number of procedural shortcomings in how the European Commission prepared several legislative proposals that it considered urgent, including the Omnibus I package. Taken together, these shortcomings amounted to maladministration.

The procedural shortcomings included failing to fully justify to the public the urgency of the legislative proposals and failing to document the Commission’s reasoning for deviating from its internal rules on law making, known as the Better Regulation rules. The reduction of the consultation time between Commission departments to less than 24 hours over a weekend for the Omnibus I package was also identified as problematic.

In her two forward-looking recommendations to the Commission, the Ombudswoman asked it to ensure a predictable, consistent and non-arbitrary application of the Better Regulation rules and to ensure that the urgent preparation of future legislative proposals is always transparent, evidence-based and inclusive. The Ombudswoman also made a number of suggestions in light of the upcoming revision of the Better Regulation rules.

• See NGO press release (18 April 2025)
• See European Ombudsman press release (22 May 2025)
• See European Ombudsman press release (14 July 2025)
• See European Commission’s response (9 September 2025)
• See European Ombudsman press release (27 November 2025)
• See  Ombudsmen Recommendations (27 November 2025) 

Separately, ClientEarth commissioned a law firm to assess the legal risks of the Omnibus I proposal should it be passed into law. In a legal opinion published on 24 June 2025, the law firm identified several grounds for legal challenge to the proposal, including violations of the principles of proportionality, legal certainty, legitimate expectations, coherence, and environmental integration, as well as the Charter of Fundamental Rights. The analysis warns that breaches of essential procedural requirements could lead to the Omnibus I being found invalid. The legal opinion also notes that these legal challenges could be brought before European Union courts by EU institutions, Member States, civil society organisations, and private operators. However, so far, ClientEarth have not indicated that they intend to commence legal proceedings against the Commission.