Welcome to the Linklaters EU Omnibus Tracker where we track key developments in the EU's efforts to simplify existing sustainability rules.
The European Commission is in the process of simplifying existing EU regulation with a view to reducing the regulatory burden on business and boosting EU competitiveness. The Commission is aiming to cut the administrative burden across the board (not just in respect of sustainability) by at least 25% for all companies and by at least 35% for SMEs. However, the Commission has emphasised that the aim of this initiative is to simplify rather than deregulate and that it is remains committed to the EU's underlying sustainability and decarbonisation goals.
This simplification initiative is being done via a series of “Omnibus” packages and other simplification measures. An “Omnibus regulation" is basically a way of using one legislative act to make changes to several existing legislative acts at the same time.
This tracker focuses on simplification measures aimed at sustainability rules.
We will be updating this tracker in “real time” as and when there are new key developments.
This table was last updated on 28 November 2025.
| EU INITIATIVE | STATUS | MORE INFORMATION |
|---|---|---|
First Omnibus package (Omnibus I)
| The Commission published the first Omnibus package (Omnibus I) on 26 February 2025. These proposals now need to be negotiated and adopted by the European Parliament and Council (discussed in more detail below).
| The first Omnibus package proposes changes to the:
Linklaters - EU: Commission publishes first Omnibus package with changes to CSRD and CSDDD Linklaters - EU: European Commission sets out proposals to simplify Taxonomy Delegated Acts Linklaters - EU: Commission proposes changes to Carbon Boarder Adjustment Mechanism (CBAM) as part of first Omnibus package Linklaters - Webinar recording: What the EU's first Omnibus package means for financial services firms |
| “Stop-the-Clock” Directive | 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:
Delay to CSRD:
Delay to CSDDD:
Linklaters - EU: Omnibus "Stop-the-Clock" Directive published in Official Journal of the EU Linklaters - EU Stop-the-Clock Directive transposition tracker |
Requirements proposal (part of Omnibus I)
| The Commission published the Requirements proposal on 26 February 2025, as part of the first Omnibus package. The Council agreed its negotiating position (aka “general approach”) on 23 June 2025. Parliament agreed its position on 13 November 2025. Negotiations between the Council and the Parliament ("trilogues") started on 18 November. | The Requirements proposal makes substantive changes to the CSRD and CSDDD, including changes to reduce the number of CSRD in-scope companies by about 80%. Linklaters - EU: Commission publishes first Omnibus package with changes to 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 Requirements Proposal – Parliamentary vote outcome Linklaters - EU Omnibus I: Parliament agrees its negotiating position on changes to the CSRD and CSDDD |
| Taxonomy proposal | The Commission published on 26 February 2025, as part of the first Omnibus package, a call for evidence on proposed amendments to the:
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”). During the ECON-ENVI Committee meeting on 6 October it was confirmed that the Parliament has informed the Commission and Council of the request for extension of a scrutiny period for an additional 2 months – until 5 January 2026. 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. 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 them (in doing so, they can ask the Commission to amend the text in whole or part). The changes in the Delegated Act were intended to apply from 1 January 2026. | 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 |
CBAM simplification and wider review
| The Commission published on 26 February 2025 a proposal for a Regulation amending the existing CBAM Regulation, as part of the first Omnibus package. The European Parliament has formally adopted the proposal on 10 September. The Council has also adopted the proposal on 29 September. The legislative act was published on 17 October and came into force on the 20 October. The Commission has also launched a consultation on a wider review of the CBAM. The consultation closes 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? |
| Changes to European Sustainability Reporting Standards (ESRS) | 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 public consultation that closed on 29 September 2025. EFRAG has revised the draft ESRS following the public consultation. The first (unapproved) drafts were released before EFRAG TEG meeting on 24 November. EFRAG SRB approved the drafts of the revised ESRS on 28 November. The final revised ESRS will be presented by EFRAG during the public session on 4 December. Meanwhile, the Commission adopted, on 30 July 2025, a Recommendation on voluntary sustainability reporting for non-listed small and medium-sized companies (SMEs). 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 first Omnibus package. The Commission has also proposed (in the Requirements proposal) to remove the power for the Commission to adopt sector-specific ESRS. 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 |
| “Quick Fix” proposal | 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 will come into force on 13 November 2025. It applies with respect to financial years beginning on or after 1 January 2025. | According to the current ESRS, “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. Moreover, 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. |
| Simplification of EU Deforestation Regulation (EUDR) | 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). 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. On 19 November and 26 November 2025, the Council and the Parliament, respectively, adopted their negotiating positions. On 4 December the Council and the Parliament reached political agreement on this file. The Parliament will vote to approve the agreement during its 15-18 December 2025 plenary session. The text agreed must then be endorsed by both Parliament and Council and be published in the Official Journal of the EU. | 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:
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:
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
|
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 the Commission published 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 Linklaters - SFDR 2.0: What you need to know Linklaters - recording of the webinar on the SFDR 2.0 proposals and their practical implications for the industry Commission - Commission simplifies transparency rules for sustainable financial products |
| Fourth Omnibus (Omnibus IV), including proposal on batteries and small mid-caps | 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 position on the SMC Proposal. The European Parliament has yet to reach a 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:
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 |
| Circular Economy Omnibus | The Commission is expected to publish a Circular Economy Omnibus in Q4 2025. | 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 |
| Environmental Omnibus | The Commission published a call for evidence on 22 July 2025. This closed on 10 September 2025. The results of the call for evidence will help inform an Environmental Omnibus in Q4 2025 - which might be published on 3 December 2025 (TBC).
| The Commission launched a call for evidence seeking views on how to simplify and streamline administrative requirements related to the environment in the areas of circular economy, industrial emissions and waste management. The call for evidence does not identify which pieces of existing environmental legislation might be simplified. Instead, it merely refers to a limited number of policy areas that may be included in the forthcoming Environmental Omnibus but acknowledges that the final list could evolve once the Commission has examined the results of the call for evidence. Linklaters - EU: Commission launches call for evidence to inform forthcoming Environmental Omnibus |
| Energy Omnibus | According to the Commission 2026 Work Programme, the legislative proposal to simplify energy product legislation will be released in Q2 2026.
| See Commission 2026 Work Programme |
| Chemicals Omnibus (“Omnibus VI”) | 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. Council gave its final sign off on 17 November 2025. The legislative act will now be published in the Official Journal of the EU in the coming days and enter into force on the 20th day after this publication. On 5 November, Council adopted its position on the second part of Omnibus VI. | This Chemicals Omnibus consists of three legislative proposals:
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 |
| Defence Omnibus | 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 - Communication from the Commission to the European Parliament and the Council |
Recommendations of the European Ombudswoman on the first Omnibus process following NGOs complaint
| A formal complaint was filed 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.
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 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, ClientEarth have not indicated that they intend to commence legal proceedings against the Commission at this stage. |
| Food and Feed Safety Omnibus | The Commission has announced an upcoming Omnibus regulation related to food and feed safety. The Delegated Regulation is planned for publication by the end of 2025 and will be preceded by a call for evidence, although the timing of this call has not yet been announced.
| The Commission intends to adopt a Delegated Regulation aimed at increasing the competitiveness of EU farmers and the food and feed industry, as well as reducing the administrative burden associated with marketing authorisations of products. The Regulation is expected to:
|
/Passle/5f6c57568cb62a0d7c9eadee/SearchServiceImages/2025-12-05-15-04-22-182-6932f476c95179a7733dbc53.jpg)
/Passle/5f6c57568cb62a0d7c9eadee/SearchServiceImages/2025-12-02-12-01-59-878-692ed537de03c50ed48050a1.jpg)
/Passle/5f6c57568cb62a0d7c9eadee/SearchServiceImages/2025-11-27-13-29-53-697-692852519b05efae39caf2e5.jpg)
/Passle/5f6c57568cb62a0d7c9eadee/SearchServiceImages/2025-11-27-14-58-56-308-692867305a6bd6a9110e7497.jpg)