On February 26, 2025, the European Commission unveiled the European Clean Industrial Deal, a bold roadmap for competitiveness and decarbonization. With a €100 billion EU fund, this initiative aims to drive electrification, lower energy costs, and boost circular materials and products. The Commission will propose many new acts, laws and directives in 2025 and 2026 to bring the European Clean Industrial Deal to life. Next to the strong push for more sustainable industry and tech, the EU Commission also aims to reduce the ‘administrative burden’ for companies, using ‘Omnibus’ legislations. While there will be several Omnibus-proposals, all with the intention to simplify and connect existing regulations, their first proposal to the European Parliament, targeted the CSRD, CSDDD, CBAM and EU-Taxonomy.
Omnibus I: CSRD, CSDDD, CBAM and EU-Taxonomy
The most important proposed changes are those related to the CSRD.
- Increasing the threshold of company size to minimal of 1000 employees instead 250 employees.
- Delay mandatory reporting for 2 years, if your company is part of wave 2 (non-EU listed companies).
- Stronger Value Chain Cap to protect companies with < 1000 employees from too many ESG-related data requests.
- Change the assurance to limited assurance only and give more guidelines on the assurance in 2026.
- Reduce the number of mandatory ESRS datapoints.
In addition, the EU-Taxonomy is considered only relevant for companies with >450 million of revenue and the ESG-Due Diligence (CSDDD) will be changed in a risked based approach, focussing on the direct suppliers. The implementation of CSDDD is delayed for one additional year. The CBAM threshold will be put higher, and many details will be simplified.
Since Omnibus I is still a proposal from the European Commission, nothing has been finalized yet. As a legislative proposal, it marks only the first step in a long process, and further changes are inevitable—some minor revisions have already been made. From here, the proposal will move through several key stages: first reading, negotiations, second reading, conciliation, third reading, adoption, and finally, implementation. While there is strong support for the European Clean Industrial Deal in both the European Parliament and the European Council, the extent to which all its components—including Omnibus I—will be backed remains uncertain. More clarity is expected after summer 2025.
Our vision on Omnibus I
The proposal to simplify existing regulation, based on the recommendations of the Draghi-report, is the result of many companies complaining about too complex and not connected ESG regulations. This push for simplification is welcome—our work with clients has revealed multiple inconsistencies in the implementation of these legislations.
We have always believed that, and compliance are not the end goals of the CSRD, CSDDD, and EU Taxonomy. The real objective is to drive decarbonization and circularity while ensuring no significant harm to other ESG priorities.
At the same time, this debate highlights a fundamental truth: sustainability is complex. It’s not just the regulations that make it challenging sustainability itself is rocket science and often underestimated by businesses.
In practice, we saw many projects initially starting as a more strategic way of understanding the sustainability of a company, grows partly into a more ‘thick the box’ exercise. We see that the CSRD create a Green and Social Buzz in organisations. Not only with the people involved, but also management and board. The CSRD has developed into the lever to understand the sustainable impact, risks and opportunities of a companies. The Clean Industrial Deal and Omnibus I present a unique opportunity for companies committed to tackling Europe’s sustainability challenges. With a strong focus on decarbonization, renewable energy, and circularity, this initiative shifts attention away from pure reporting and compliance and toward real environmental and social progress.
What to do next?
Even if your company is no longer required to publish a sustainability report, you may still need a robust framework to guide your ESG efforts. The ESRS has proven to be a valuable tool, seamlessly integrating into many companies’ existing net-zero, zero waste, or other sustainable and circular strategies. Beyond your strategic ambitions, ESG will remain a critical focus for many stakeholders across your value chain. Understanding this chain and identifying which stakeholders are key to align with or collaborate on is a value-adding activity. While engaging stakeholders is essential, we’ve observed that many companies, in their CSRD efforts, focus too much on simply sending out questionnaires. True engagement, however, is about fostering a deeper understanding of your business, building stronger collaboration, and not just on the ESG front. It’s also likely that stakeholders will continue to request ESG data to assess the environmental impact of products. Consider the need for an Environmental Product Declaration or greater product transparency in the supply chain, such as the Digital Product Passports under the ESPR)
We recommend continuing to develop your sustainability reporting, particularly around the material topics relevant to your business. If you’ve already invested in this area, build upon that investment. You may not need to accelerate, but don’t stop, or you risk losing the value you’ve gained. The additional time provides a unique opportunity to better integrate sustainability into your core strategy, which will be appreciated by investors, employees, value chain partners, and in the long run, will enhance value creation.
Even if your company is not mandated to report, we strongly encourage you to either start or continue your sustainability reporting. It’s not just about compliance—it’s about bringing your sustainability strategy to life. Reporting requires a fresh perspective on your business model, leading to more sustainable value. Plus, it’s the ideal way to communicate with both internal and external stakeholders about where your company stands and how decarbonization aligns with your business goals.
Ultimately, sustainability is about more than just reporting or financial outcomes—it’s about creating a better world for future generations.