EU: Parliament JURI Committee approves its negotiating position on Omnibus changes to CSRD and CSDDD

On 13 October 2025, the Legal Affairs Committee of the European Parliament (also known as the JURI Committee) approved its report on the Omnibus I Requirements Proposal. While a consolidated text of the report is not yet available, the agreed draft text has been published alongside the Parliament press release.

Here are the key points agreed by the JURI Committee regarding amendments suggested by the Commission to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD or CS3D):

CSRD

• CSRD scope: The JURI Committee has proposed increased scoping thresholds for both EU and non-EU companies from the Commission’s original proposal. 

  • EU companies: Companies with more than 1,000 employees and a net annual turnover exceeding EUR 450 million will be in scope. 

  • This also applies to sustainability reporting under the EU Taxonomy. For companies no longer covered by the CSRD, reporting would be voluntary, as proposed by the Commission. 

  • Non-EU companies: Companies with: (i) a net annual turnover exceeding EUR 450 million generated in the EU (in line with the Commission’s original proposal); and (ii) an EU subsidiary or branch with a net annual turnover exceeding EUR 450 million (up from the Commission’s original proposal), will be in scope. 

• CSRD value chain cap: In-scope reporting companies may only request sustainability information from value-chain entities that that have below 1,000 employees and EUR 450 million net turnover if: (i) that information is included under the voluntary sustainability reporting standards, or (ii) that sustainability information is commonly shared in the relevant sector. The CSDDD contains a similar provision limiting the information that can be requested. 

• Data sharing and blocking legislation provisions: Where third-country laws restrict non-EU companies from sharing sustainability information with the EU in-scope reporting company, the EU in-scope reporting company may use default values. In this case, the EU in-scope reporting company must explain the actions undertaken (and any plans to obtain the data) and notify the supervisory authority accordingly. 

• Transition plans: No change to the Commission’s original proposal. 

CSDDD

• CSDDD scope: Whereas the Commission’s original proposal did not envisage any changes to the CSDDD scope, the JURI Committee wants to raise the thresholds for both EU and non-EU companies. 

  • EU companies: Companies with more than 5,000 employees and a net annual turnover above EUR 1.5 billion. 

  • Non-EU companies: Companies with a net annual turnover above EUR 1.5 billion in the EU.

• Due diligence: The JURI Committee has adopted a risk-based approach that seeks to more closely align with the UNGPs, requiring companies to: 

  1. carry out a scoping based on reasonably available information to identify general areas where adverse impacts are most likely to occur and to be most severe across their own operations, those of their subsidiaries and their business partners (where related to their chains of activities); and 

  2. based on the results of the scoping, and where the company has grounds to believe that adverse impacts have arisen or may arise, carry out a further assessment in areas where adverse impacts were identified to be most likely to occur and to be most severe. 

The JURI Committee’s proposal includes limitations on the ability for companies to obtain information from their business partners, particularly where the business partner has fewer than 5,000 employees. 

• Transition plans: The JURI Committee has opted to retain the requirement for companies to adopt transition plans under the CSDDD. However, the following key changes have been proposed:

  • Implementation: The reference to “implementing actions” has been deleted, meaning the requirement focuses on adoption and disclosure of a transition plan rather than its implementation. The JURI Committee has retained the requirement for transition plans to be updated every 12 months accompanied by a brief description of progress.

  • The reference to “best efforts” has been replaced with the lower standard of “reasonable efforts”, which are defined as taking proportionate and reasonable actions aiming to ensure compatibility with the transition to a sustainable economy in line with the Paris Agreement, without having to exhaust all possible means at their disposal.  

  • 1.5℃: The reference to "1.5℃ in line with the Paris Agreement" has been deleted. The JURI Committee instead refers only to the Paris Agreement and has also removed the reference to compatibility with intermediate and 2050 climate neutrality targets in relation to the EU Climate Law.

  • Mandatory design features: Certain mandatory design features for transition plans have been retained. This contrasts with the Council, which proposes removing all mandatory design features and making them optional. 

  • Role of supervisory authorities: Supervisory authorities are to supervise the adoption of transition plans not the implementation and design. The JURI Committee has included guidance for supervisory authorities directing them to take into account, inter alia, the difficulties inherent in estimating future GHG emissions, the effectiveness and availability of certain climate change mitigation technologies, levers and actions over time, and the overall complexity and evolving nature of climate transitioning.  

  • Grace period for transition plan adoption: Unlike the Council, which provides a two-year grace period for mandatory transition plan adoption, no grace period has been identified in Parliament's position. 

• Civil liability under the CSDDD: Under the JURI Committee’s proposal, in-scope companies would be liable for damages caused by breaches of due diligence obligations under national law, rather than at the EU level.  

The JURI Committee proposes establishing a maximum penalty limit of 5% of net worldwide turnover (or consolidated worldwide turnover for certain company categories). This represents a change from the Commission's original proposal, which removed the original CSDDD provision that set the maximum at 'not less than 5%' (a minimum maximum).

Next steps

The Council agreed its negotiating position (also known as “general approach”) on 23 June 2025 (see our previous blog post). 

According to the European Parliament's press release, if the Parliament approves the JURI Committee’s mandate at its next plenary session (expected on 20 October), the negotiations (trilogues) between the Parliament and Council on the final text of the Omnibus I Requirements Proposal will begin on 24 October. 

The first trilogue is expected to be a high-level meeting in which the institutions (Parliament, Council, and Commission) present the main points of their respective negotiating positions.

For more information on the CSRD and Omnibus, see our CSRD Quick Guide and Omnibus Tracker.