EU: Council and Parliament reach political agreement on amendments to CSRD and CSDDD under Omnibus I

In the early hours of 9 December 2025, the European Parliament and the Council announced that they had reached a political agreement on changes to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD or CS3D) that form part of the Omnibus I proposal. 

The Parliament press release is available here, the Council press release here and the Commission press release here. Jörgen Warborn, the European Parliament rapporteur, and Danish Minister for Industry, Business and Financial Affairs Morten Bødskov held a press conference to announce the provisional agreement.

The final text of the agreement is not yet available. However, the press releases from the co‑legislators set out the following key elements of the deal:

CSRD

• EU companies would fall within scope if they have more than 1,000 employees and an annual net turnover of more than EUR 450 million.

• For non‑EU companies, the net turnover threshold was increased to EUR 450 million generated in the EU. During the press conference, Mr Warborn also mentioned a EUR 200 million turnover threshold for branches / subsidiaries, though further details are not yet available.

• Companies with fewer than 1,000 employees would be able to refuse to report information beyond what is set out in the voluntary standards.

• Financial holding undertakings will be exempted from CSRD reporting, under certain conditions yet to be communicated. In the context of CSDDD, for instance, to benefit from an exemption holding companies must not engage in taking management, operational or financial decisions affecting the group or one or more of its subsidiaries. 

• Mr Warborn also mentioned at the press conference the “full subsidiary exemption”, although he did not give any further details. The scope of this exemption will therefore need to be confirmed when the final agreed text is available.

• The CSRD will include a “transition exemption” for companies that started reporting for financial year 2024 (the “first wave”) but will fall out of scope based on the changes introduced by Omnibus I.

• The Commission will create a digital portal for businesses, providing access to templates and guidelines on EU and national reporting requirements.

• Co-legislators also agreed on the simplification of the reporting requirements which should become more quantitative, while sector-specific reporting would become voluntary. Meanwhile EFRAG has already delivered to the Commission the revised European Sustainability Reporting Standards (ESRS). The Commission will now prepare the Delegated Act revising the existing set of ESRS based on EFRAG’s technical advice. For more information, see our blog post. 

CSDDD

• EU companies would fall within scope if they have more than 5,000 employees and an annual net turnover of more than EUR 1.5 billion.

• Non‑EU companies would fall within scope if they have a net turnover in the EU of more than EUR 1.5 billion.

• The requirement in the CSDDD to produce a climate transition plan has been removed entirely. However, the requirement under the CSRD to disclose a transition plan, if the company has one, remains.

• In relation to Article 8 of the CSDDD on supply chain due diligence, Mr Warborn said during the press conference that the agreement is a compromise between the two different positions the co‑legislators had at the start of the trilogues. The final agreement provides that companies can focus on the areas of their chains of activities where actual and potential adverse impacts are most likely to occur. Where a company has identified adverse impacts that are equally likely or equally severe in several areas, it is given the ability to prioritise assessing adverse impacts that involve direct business partners. Companies are expected to base their efforts on reasonably available information and should refrain from requiring unnecessary information from companies that are not within the scope of the CSDDD.

• Provisions in the current CSDDD on harmonised (EU-wide) civil liability are removed. The civil liability would be defined by the national law of each Member State. Fines cannot exceed 3 per cent of net worldwide turnover.  

• The deadline for transposition of the CSDDD has been postponed by one year to 26 July 2028, with companies required to comply with the new measures by July 2029.

• The provisional agreement introduces a review clause concerning a possible extension of the scope for both the CSRD and the CSDDD.

Next steps

The final agreed text must now be endorsed by both co‑legislators. 

In the Parliament, the Legal Affairs Committee is scheduled to vote to approve the deal on 11 December 2025, and a vote in the plenary is planned for 16 December 2025. 

The Council has not yet confirmed the date on which it plans to give its final approval.

The Omnibus I amendments will then be published in the Official Journal of the European Union. They will enter into force on the 20th day following publication.

Further information

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