You’ve probably already seen it passing by in the news or on LinkedIn: on February 26, OMNIBUS I was published. But what exactly does this mean for your organization and how do you deal with it? In this article, we explain.
What is Omnibus anyway?
On Feb. 26, 2025, the European Commission launched the European Clean Industrial Deal: an ambitious plan to make Europe more competitive and sustainable. With a €100 billion fund, the EU wants to stimulate electrification, reduce energy costs and accelerate the transition to circular materials and products.
To achieve this, there will be many new laws and directives in 2025 and 2026. But at the same time, the EU Commission also wants to reduce the administrative burden on companies. Therefore, “Omnibus” laws are in the pipeline, which should simplify and better connect existing regulations.
The first proposal, Omnibus I, focuses specifically on four key sustainability laws: the CSRD, CSDDD, CBAM and EU Taxonomy.
Key changes for your organization
- The proposal brings sweeping changes especially for the CSRD:
- The threshold shifts from 250 to 1,000 employees, requiring far fewer companies to report
- Wave 2 (non-EU listed companies) gets two-year reprieve
- Smaller companies (< 1000 employees) get better protection from excessive ESG data queries through a Value Chain Cap
- There will be limited assurance requirement only, with clearer guidelines starting in 2026
- The number of mandatory ESRS data points is reduced
Other legislation is also changing: the EU Taxonomy becomes relevant only for companies with more than €450 million in turnover, the CSDDD shifts to a risk-based approach with a focus on direct suppliers and goes into effect a year later, and the CBAM threshold goes up with simpler requirements.
The main proposed changes have now been published, with some minor revisions already made. It is important to realize that this is still a proposal. We expect more clarity on the final changes after the summer of 2025, after going through the legislative process.
Our take on Omnibus I: opportunities rather than obstacles
The call for simplification did not come out of the blue. Many organizations complained about complex and fragmented ESG regulations. The proposal to simplify existing regulations is based on the recommendations of the Draghi Report. Our work with clients also shows that there are indeed inconsistencies in current legislation.
At Empact, we have always stressed that compliance is not the end goal of laws like the CSRD, CSDDD or EU Taxonomy. The real goal is to bring about meaningful change: CO2 reduction, circular economy and damage prevention on other ESG topics.
At the same time, this debate makes clear: sustainability is complex. It’s not just the rules that make it complicated – sustainability itself is a challenging field that companies often underestimate.
In practice, we see that projects that begin as a strategic exploration of sustainability sometimes degenerate into a box-ticking exercise. But we also notice that the CSRD creates a positive dynamic in organizations. Not only with those directly involved in the theme, but also with management and the board. The CSRD has developed into a powerful lever for structurally mapping out the sustainable impact, risks and opportunities.
The Clean Industrial Deal and Omnibus I therefore offer opportunities precisely for companies that take Europe’s sustainability challenges seriously. The focus shifts from pure reporting to actual environmental and social progress.
What to do next? Our recommendations
Even if your organization will soon no longer be required to publish a sustainability report, you still need a solid framework for your ESG efforts. The ESRS has proven to be a valuable tool that fits seamlessly with many companies’ existing net-zero, zero waste or other sustainable strategies.
Remember that ESG remains an important issue for stakeholders in your value chain, regardless of reporting requirements. Understanding this chain and knowing which stakeholders to work with provides direct value. Our advice: look beyond sending questionnaires and go for real engagement that leads to a deeper understanding of your company.
In addition, stakeholders will continue to demand ESG data to assess environmental impacts of products. Prepare for the demand for Environmental Product Declarations or greater transparency in the supply chain, such as through Digital Product Passports under the ESPR.
Our main advice: keep developing your sustainability reporting, especially around the topics that are really relevant to your business. If you’ve already invested in this area, build on it. You may not need to accelerate, but certainly don’t stop – otherwise you’ll lose the value you’ve built.
The extra time you get now provides a unique opportunity to better integrate sustainability into your core strategy. This is appreciated by investors, employees and supply chain partners, and increases your value creation in the long run.
Even if you are not required to report, we strongly encourage you to start or continue your sustainability reporting. It’s not just about compliance – it’s about really bringing your sustainability strategy to life. A sustainability report forces you to look at your business model with fresh eyes, leading to more sustainable value. Moreover, it is the ideal way to communicate with internal and external stakeholders about where you stand and how sustainability contributes to your business goals.
Because ultimately, sustainability is about more than reporting or financial results – it’s about creating a better world for future generations.