EU Omnibus I: Parliament agrees its negotiating position on changes to the CSRD and CSDDD

On 13 November 2025, after months of intense and often unpredictable negotiations, the European Parliament adopted its position on the Requirements Proposal (see Parliament press release).

The Requirements Proposal forms part of the Omnibus I package and introduces substantive changes to the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD or CS3D). For more information on the Requirements Proposal, see our previous blog post. 

The text agreed by the Parliament is not yet available. According to the press release, here are key points from the Parliament’s position:

CSRD

• Scope: For EU companies, the Parliament wants to increase the employee threshold to 1,750 employees (compared to 1,000 in the Council’s position) and sets a turnover requirement at EUR 450 million (which is consistent with the Council’s position). The press release did not provide details on the position for non-EU companies.

• Taxonomy reporting: The same scope as the CSRD will apply, in line with both the Commission proposal and the Council’s position (although both positions have different application tests).

• ESRS: Reporting standards would be simplified and reduced, requiring fewer qualitative details. Sector-specific reporting would become voluntary. This is broadly in line with the Commission proposal and the Council’s position.

• Value chain cap: Companies reporting under the CSRD would not be permitted to request information from out-of-scope companies beyond what is required under the voluntary standards. While this position is aligned in principle with the Commission’s and Council’s views, the Parliament press release did not give details on this point and there may be different views as to how the value chain cap should be implemented (once the final text of the Parliament’s position is available).

• Digital portal: The Parliament called for the Commission to establish a digital portal for businesses, providing free access to templates, guidelines, and information on all EU reporting requirements, complementing the European Single Access Point (ESAP).

CSDDD

• Scope: The Parliament wants an employee threshold of 5,000 employees and a turnover requirement of EUR 1.5 billion for EU companies, in line with the Council’s position. There was no information in the press release regarding non-EU companies.

• Transition plan: The Parliament wants to delete the mandatory transition plan requirements under Article 22 of the CSDDD. This differs from the Council’s position, which maintains the obligation to have a transition plan albeit with some reliefs.

• Due diligence: MEPs voted for a risk-based approach to due diligence under Article 8 of the CSDDD. During the press conference, Jörgen Warborn (rapporteur) noted that the Parliament proposes a different model to the Council, which focuses on own operations and tier 1 business partners. Further negotiations are expected on this point. 

• Value chain cap: In-scope companies should rely on already available information and only request additional information from their smaller business partners as a last resort. The press release did not provide further details.

• Civil liability: Those in breach of the Directive’s due diligence requirements would be liable at the national rather than EU level and would have to fully compensate victims for damages. This is similar to the approach taken by both the Commission and the Council.

Next steps 

The Council approved its negotiating position on the Omnibus I proposal on 23 June (see our previous blog post) so trilogues (negotiations between the Parliament and Council) can now start. 

According to the Parliament press release, trilogues will begin on 18 November. 

The parties are hoping to finalise negotiations by the end of 2025, although it is difficult to predict whether this will be achieved given differences in the co-legislators’ positions on some of the key issues.

Further information

See our EU Omnibus Tracker for details on the current status of other changes to EU sustainability rules.