Omnibus Initiative: New developments in sustainability reporting

published on 25 June 2025 | reading time approx. 2 minutes

The Omnibus initiative to strengthen the competitiveness of the European Union (EU) is gaining momentum: As part of the “Omnibus I” sustainability package published on February 26, 2025, the “Stop-the-clock” Directive (EU) 2025/794 on the postponement of ESG reporting obligations came into force on April 17, 2025.

For companies currently subject to the Corporate Sustainability Reporting Directive (CSRD), this means the following:

Companies subject to NFRD (“Wave 1”): The CSRD reporting obligation remains in place, as companies that have been subject to reporting requirements since the 2024 financial year are not covered by the “stop-the-clock” directive. In Germany, however, due to the still pending national implementation of the CSRD, the Non-Financial Reporting Directive (NFRD), the predecessor directive transposed into national law, will continue to apply until further notice.
All other large companies (“Wave 2”): The date of mandatory first-time application is postponed by two years to financial years beginning on or after January 1, 2027.
Capital market-oriented SMEs (“Wave 3”): The date of mandatory first-time ap-plication is postponed by two years to financial years beginning on or after January 1, 2028, for small and medium-sized enterprises (SMEs).

However, amendment COM(2025) 81, which is also included in the “Omnibus I" package, could significantly reduce the number of users in the future: Among other things, the current proposal of the EU Commission provides for an increase in the threshold to 1,000 employees. The proposal is currently in the legislative process at the level of the EU Parliament and the EU Council of Ministers. It thus remains to be seen to what extent this proposed directive will be amended in the course of negotiations at EU level and when the changes will come into force.

The deadlines are also changing for certain companies that fall under the Corporate Sustainability Due Diligence Directive (CSDDD): Large companies with more than 5,000 employees and annual revenues of over €1.5 billion must now comply with the new due diligence requirements from 2028 — one year later than originally planned.

Furthermore, on March 27, 2025, the EU Commission commissioned the European Financial Reporting Advisory Group (EFRAG) to revise the European Sustainability Reporting Standards (ESRS). An initial public consultation ran until May 6, 2025, after which the revision phase began. As part of this, EFRAG submitted a progress report to the EU Commission on June 20, 2025, outlining the six key levers for simplifying the ESRS. The first drafts are to be published at the end of July 2025 and, following a further consultation and revision phase, submitted to the European Commission by October 31, 2025.

Regardless of regulatory requirements, ESG reporting remains an important issue — not least due to demands from investors, banks, and customers. According to the Omnibus proposal, the EU will develop a voluntary standard for sustainability reporting for companies not subject to CSRD reporting requirements based on the Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME Standard) developed by EFRAG and adopt it as a delegated act. We will keep you informed on this matter.

You can find more detailed information on the latest developments surrounding the Omnibus initiative in this in-depth article from our ESG News.