The EU Omnibus I and II packages

On 26 February 2025, the EU Commission published the first two of its omnibus simplification packages with the intention of simplifying rules, reducing the compliance burden, boosting competitiveness and unlocking investment capacity in the EU.

Omnibus I and II would, if adopted, have significant impacts on the EU's rules in relation to corporate sustainability reporting and due diligence, as well as the EU's Carbon Border Adjustment Mechanism (CBAM).

Key proposals include:

Corporate Sustainability Reporting

• Delay of the Corporate Sustainability Reporting Directive by 2 years
• Reduction of scope of corporate sustainability reporting (estimated at 80% by the Commission)
• Removal of the requirement for reasonable assurance of sustainability reports
• Reduction in impact of sustainability reporting requirements on value chain actors
• Proposed amendments to the European Sustainability Reporting Standards and abandoning the development of sector specific standards

EU Taxonomy

• A new "opt in" taxonomy reporting framework, including proposals for partial taxonomy alignment
• Commission consultation on Level 2 taxonomy acts (both "Article 8" reporting and technical screening criteria)

Corporate Sustainability Due Diligence

• Delay of the Corporate Sustainability Due Diligence Directive by 1 year
• Reducing the potential for Member State "gold plating" of due diligence requirements
• Limiting assessment of adverse impacts within the "chain of activities"
• Reducing scope of stakeholder engagement requirements
• Changes to the penalties and civil liability regimes

Carbon Border Adjustment Mechanism

• Introduction of de minimis threshold for small importers
• Simplification of CBAM obligations
• Measures to make CBAM more effective

InvestEU

• Unlocking additional capacity in private and public investment
• Reducing compliance burden on participants in the InvestEU value chain.

The Omnibus packages are just proposals at this stage - they will be subject to trilogue negotiations with the EU Parliament and the Council before we will know what the final rules will look like.  However companies (both EU and non-EU) will need to stay on top of these developments to understand where they could end up.  To help you in navigating these proposed changes (as well as the complementary changes proposed to Level 2 Taxonomy acts and the European Sustainability Reporting Standards), we have prepared a comprehensive client note.