EU Omnibus Tracker: simplification of sustainability rules

 Status

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

More information

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.

Status

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.

More information 

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). 

For more information, see:

• Linklaters - EU: Omnibus "Stop-the-Clock" Directive published in Official Journal of the EU
• Linklaters - EU CSRD and Stop-the-Clock Directive transposition tracker
   

Status 

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 endorsed that political agreement on 16 December 2025, and the Council gave its formal approval on 24 February 2026. 

The Omnibus I Directive was published in the Official Journal of EU on 26 February 2026. 

Member States must transpose the Directive into national law by 19 March 2027, except for the provisions related to the CSDDD which shall be transposed by 26 July 2028.

More information

The Requirements proposal (which was 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.

The final text was published in the Official Journal of the EU on 26 February 2026. See Linklaters - EU Omnibus I Directive published in the Official Journal of the EU.   

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
• Linklaters - EU Omnibus I: CSRD and CS3D amendments finalised: what do you need to know?
• Linklaters - EU: changes to CSRD and CSDD under Omnibus I reach the finish line: video

Status 

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 “scrutiny period”). 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 Delegated Act was published in the Official Journal of the EU on 8 January 2026.

The Commission published Commission Notice in the form of FAQs on these changes (fourth Notice). It explains that, for 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 applies as of 1 January 2026; or
• they can apply the version of the reporting rules that were applicable until 31 December 2025, in which case they must apply those rules in full. 

More information 

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%.

For more information, see:

• 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
• Linklaters - EU: Delegated act on simplifying Taxonomy Reporting published in the Official Journal
• Commission FAQs (fourth notice)

Status

The Commission sought feedback on potential revisions to the technical screening criteria (TSC) in the EU Taxonomy. 

The changes cover the majority of activities under the Climate and Environmental Delegated Acts, including forestry and environmental protection, manufacturing, energy, transport and construction. Proposals also include revisions to clarify the Do No Significant Harm (DNSH) criteria. 

The feedback period was open until 14 April 2026. 

The Commission planned to adopt the final version of the revised Delegated Act by June 2026. However, we are still waiting for this.  

Legislators will then have a scrutiny period of two months (extendable by another two months). 

The revised Delegated Acts are planned to apply from 1 January 2027.

More information 

Linklaters - EU: Commission seeks feedback on revisions to simplify the technical screening criteria under the EU Taxonomy

Status 

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 also launched a consultation on a wider review of the CBAM.  The consultation closed on 26 August 2025. 

On 17 December 2025, the Commission published a proposal to extend the scope of the CBAM to include 180 steel and aluminium-intensive downstream products from 1 January 2028 and measures to close loopholes to prevent circumvention of the CBAM (see Commission  press release,  Q&A and Proposal). The draft Regulation now needs to be negotiated and adopted by the European Parliament and Council.

Status

EFRAG delivered their recommendations on the revised ESRS to the Commission on 3 December 2025.  

On 6 May 2026, the European Commission launched two consultations:

• consultation on the revised European Sustainability Reporting Standards (ESRS); and 

• consultation on the Sustainability Reporting Standard for Voluntary Use. 

Both consultations closed on 3 June 2026. 

Commission adoption of both the revised ESRS and voluntary standards is planned for Q2 2026. 

The standards will then be subject to scrutiny by the Council and the European Parliament for two months (extendable by two months). 

The standards for voluntary use are based on the Recommendation on voluntary sustainability reporting for non-listed  SMEs, although with certain changes. 

The CSRD requires the Commission to adopt the tailored ESRS for certain non-EU companies operating in the EU (N-ESRS). According to the EFRAG Work Programme, EFRAG intends to consult on the draft N-ESRS from July to October 2026 and this will feed into technical advice to be delivered by EFRAG to the Commission by January 2027. 

More information 

The Commission is revising 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 by the Omnibus I Directive.   

The Omnibus I Directive introduced a value chain cap. This means that companies in the value chain with fewer than 1,000 employees have the right to decline to provide sustainability information beyond that set out in a voluntary reporting standard. The Omnibus I Directive empowered the Commission to adopt voluntary sustainability reporting standards for undertakings with no more than 1,000 employees. 

For more information, see:

• 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
• Linklaters - EU CSRD: revised ESRS and ESRS for voluntary use published for consultation

Status 

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. 

More information 

 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. 

For more information, see:

• 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

Status 

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. 

More information 

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

Next steps: 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.  

For previous coverage (in chronological order), see:

• 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

Status

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). The proposal (also known as “SFDR 2.0”) is being negotiated by the European Parliament and Council under the ordinary legislative procedure.  

Council has adopted its position on SFDR 2.0 on 24 June 2026. 

The Parliament is expected to agree its negotiating position in the third quarter of 2026.  

The Commission's proposal includes an 18-month implementation period from when SFDR 2.0 comes into effect, which means the earliest effective date for SFDR 2.0 is likely to be around early to mid-2028. 

More information

The proposed 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. 

For more information, see:

• 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
• Linklaters - EU: SFDR 2.0 - the key milestones ahead
• Linklaters - EU: SFDR 2.0 moves one step closer to trilogues as Council agrees its negotiating mandate
• Council press release - Council agrees position on simpler transparency rules for sustainable financial products

Status 

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 ("Stop-the-Clock"). The consultation closed on 23 July 2025. 

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

On 24 September, the Council agreed its negotiating position on the SMC Regulation.  Parliament adopted its negotiating position on 11 March 2026. 

On 9 June 2026, the European Parliament and Council reached political agreement. 

More information 

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:

Stop-the-clock 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).

SMC Regulation

• 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. 

For more information, see:

• 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 on its position on SMC proposal
• Council press release on the political agreement on SMC proposal

Status

The Commission is expected to publish a Circular Economy Act and Circular Economy Omnibus in Q3 2026. 

The Commission launched a public consultation and call for evidence on the Circular Economy Act in August 2025. Both closed in November 2025.

According to the “One Europe, one Market" roadmap, the Circular Economy Act is expected to be agreed on by the Parliament and the Council by Q3 2027.

More information 

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 and a Circular Economy Act in Q3 2026. 

For more information, see:

• Linklaters - EU Single Market Strategy: dealing with fragmented rules on packaging, labelling and waste
• Linklaters - European Commission takes steps to advance the circular economy

Status 

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

On 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".

The Commission launched a stakeholder consultation on the proposals, which closed on 7 May 2026. The feedback will be summarised by the Commission and fed into the ongoing legislative discussions in the European Parliament and Council.

On 24 June 2026, Council agreed its negotiating position on three elements of the Environmental Omnibus - proposals to simplify rules and procedures in the areas of industrial emissions, circular economy, and geospatial data. Two elements of the package: (i) the EPR (Extended Producer Responsibility) provisions and (ii) The regulation on speeding up environmental assessments (RSEA) failed to secure agreement and have been removed from the current mandate. The incoming Irish Presidency will continue discussions on the remaining elements of the package and will enter negotiations with the European Parliament once both co-legislators have adopted their positions.

According to the “One Europe, one Market" roadmap, all Omnibus simplification packages put forward in 2025 should be agreed on by the end of 2026. 

More information

For more information, see:

• Linklaters - EU: Commission launches call for evidence to inform forthcoming Environmental Omnibus
• Linklaters - EU: Commission publishes Environmental Omnibus
• Council - Simplification: Council agrees negotiating stance to simplify and streamline environmental rules

Status 

The Commission launched a call for evidence on the simplification of energy-efficient product legislation,  which closed on 12 March 2026. 

The Commission published Proposal for a regulation on simplification and better use of digital options for energy and tyre labelling on 24 June 2026. 

The proposal will follow the ordinary legislative procedure. 

More information 

The proposal aims to reduce administrative burdens for suppliers and retailers while maintaining clear and comparable information for consumers. Key measures include: 

• introducing more flexible display options (e.g. digital labels, QR codes, and earlier provision of labels in sales processes),
• simplifying updates when energy ratings are rescaled,
• clarifying responsibilities for non-EU manufacturers’ representatives, and
• easing certain requirements for tyre labelling (e.g. removing display obligations for car dealers). 

Commission - Omnibus simplification of energy-efficient product legislation

Status

The Commission published the Chemicals Omnibus on 8 July 2025. 

All parts of the Chemicals Omnibus need to be negotiated and adopted by the European Parliament and Council under the “ordinary legislative procedure”.

On 24 September 2025, Council approved its negotiating position on the changes to the dates of application of the CLP Regulation (which is a proposal to "Stop-the-Clock"). 

The Parliament approved these changes on 23 October 2025 and then gave its final sign off on 17 November 2025.  

The “Stop-the-Clock” Regulation was published in the Official Journal of the EU on 3 December 2025. 

On 5 November 2025, Council adopted its negotiating position on the remaining part of the Chemicals Omnibus. 

On 17 June 2026, the Parliament and the Council reached political agreement on this part of the proposal.

According to the Council press release, the co-legislators will work towards formally adopting this part of the Chemicals Omnibus as soon as possible, in the course of 2026.

More information

This Chemicals Omnibus consists of two legislative proposals:

• Proposal for a Regulation amending certain dates of application in the Classification, Labelling and Packaging of Substances and Mixtures (CLP) Regulation ("Stop-the-Clock")
• Proposal for a Regulation amending certain requirements in the CLP Regulation, the Cosmetic Products Regulation, and the Fertilising Products Regulation; and

The Stop-the-Clock part of Chemicals Omnibus postponed to 1 January 2028 the date of entry into application of the CLP Regulation. 

The provisional agreement between the Parliament and the Council on the remaining part of Chemicals Omnibus extends this date to 1 January 2030 to align the date of application CLP Regulation, the Cosmetic Products Regulation, and the Fertilising Products Regulation . Other changes made by co-legislators include: 

• CLP: Relaxed label formatting rules and extended relabelling deadlines when substances are found more hazardous than previously thought.

• Cosmetics: Risk-proportionate phase-out timelines for Carcinogenic, Mutagenic or Reprotoxic (CMR) substances, with mandatory pre-market notification for nanomaterials preserved.

• Fertilisers: Commission tasked with modernising registration requirements for components that don't fit existing categories (e.g. micro-organisms, polymers).

Together with the Chemicals Omnibus, the Commission has also published Proposal for a Regulation to strengthen the governance of the European Chemicals Agency (ECHA). It aims to provide ECHA with an autonomous legal framework, with the resources, flexibility, and structural adaptations needed to fulfil its duties under its growing mandate that consolidated governance currently spread across REACH, CLP, the Biocides Regulation, and other instruments. This proposal is now in trilogue negotiations, with both the Council (in December 2025) and Parliament (in April 2026) having adopted their respective positions (see here). 

For more information, see:

• 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
• Commission welcomes political agreement on the second part of VI Omnibus proposal
• Council press release on the political agreement on the second part of VI Omnibus proposal

Status 

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

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

The Commission Notice on the application of the sustainable finance framework and the Corporate Sustainability Due Diligence Directive (CSDDD) to the defence sector was published in the Official Journal of the EU on 30 December 2025. 

The Commission Delegated Regulation (EU) 2025/1775 of 28 August 2025 amending Delegated Regulation (EU) 2020/1818 as regards the definition of prohibited weapons was published in the Official Journal of the EU on 30 December 2025 and will apply from 30 June 2026. 

The Council approved its negotiating position on the draft Regulation amending the REACH, CLP, Biocidal Products and POPs Regulations on 26 November 2025. 

Council and Parliament reached political agreement on the Defence Omnibus on 10 June 2026.

More information 

The Defence Readiness Omnibus package comprises three legislative proposals:

• Regulation on the acceleration of permit-granting for defence readiness projects; 

• Regulation amending the REACH, CLP, Biocidal Products and POPs Regulations, as well as the European Defence Fund (EDF) Regulation; and

• Directive simplifying intra-EU transfers and security and defence procurement. 

The provisional political agreement of the co-legislators keeps the Commission’s proposed changes to EU chemicals rules, allowing Member States greater flexibility to exempt defence readiness activities from requirements under REACH, CLP, the Biocidal Products Regulation and the POPs Regulation. It also keeps the 42-working-day permitting deadline, but the co-legislators added a possible one-off 60-working-day extension for projects presenting exceptional health, safety or environmental risks. Tacit approval remains, although Member States may disapply it in limited cases where a specific project poses a grave risk to human health or national security.

• 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
• 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
• Council press release - Simplification: Council and Parliament strike deal to boost EU defence industry and readiness

Status

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

On 23 June 2026, the European Ombudsman published its Decision on the complaint. The Ombudsman closed the three cases on the basis that the Commission broadly agreed to implement her recommendations. 

More information 

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 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. 

In its reply, the Commission recognised the importance of ensuring derogations from its standard policy-making rules in the case of urgency are properly recorded and explained. As part of its plans to revise these internal rules, the Commission also indicated it will reflect on ways to be more transparent in its assessments of the need to act urgently. 

On 23 June 2026, the European Ombudsman published its Decision on the European Commission’s compliance with its ‘Better Regulation’ rules and other procedural requirements in preparing legislative proposals that it considered to be urgent. The Ombudsman closed the three cases on the basis that the Commission broadly agreed to implement her recommendations, but made clear that the effectiveness of the concrete measures remains to be assessed and that she will monitor the matter once the Better Regulation rules have been revised and applied. 

For more information, see:

• NGO press release (18 April 2025)
• European Ombudsman press release (22 May 2025)
• European Ombudsman press release (14 July 2025)
• European Commission’s response (9 September 2025)
• European Ombudsman press release (27 November 2025)
• Ombudsmen Recommendations (27 November 2025)
• Opinion of the European Commission on a recommendation from the European Ombudsman
• Decision on the European Commission’s compliance with its ‘Better Regulation’ rules and other procedural requirements in preparing legislative proposals that it considered to be urgent

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.