• Postpone the first reporting dates by two years for large companies and non-listed SMEs that have not yet started reporting ('stop-the-clock').
• Increase the thresholds for companies that are in-scope, reducing the number of companies that need to report.
• Limit the reporting requests for companies not in-scope by adopting a proportionate standard, for voluntary use, based on the VSME. 
• Abolish the requirement for a separate reporting standard for listed SMEs, small banks and captive insurers (LSME).
• Delete the possibility of moving to a reasonable assurance requirement.
• Delete the requirement for sector-specific standards.
• Simplify the ESRS.

Further details can be found in the Factsheet produced by Accountancy Europe. 

Accountancy Europe is a Brussels-based organisation that represents 45 professional organisations from 35 countries across accountancy, auditing and advisory services. ACCA is an Accountancy Europe member and contributes to its policy work, including in relation to the Omnibus Package.

• Postpone the application of requirements for the first wave of companies until July 2028 ('stop-the-clock').
• Advance the timetable for guidelines from the EC.
• Narrow the definition of stakeholder, excludes groups such as consumers, civil society organizations and others.
• Limit value chain scope to a company’s own operations, its subsidiaries and its direct business partners.
• Restrict information requests from SMEs.  
• Remove duty to terminate business relationships when adverse impacts are severe and other measures have been exhausted. 
• Decrease frequency of due diligence assessments from one to five years. 
• Remove obligation to ‘put into effect’ a transition plan and replace with an obligation to 'adopt' a transition plan with implementing actions, aligned with CSRD.

Further details can be found in the Factsheet produced by Accountancy Europe.

Insights from ACCA on CSDDD and its benefits can be found in the article Sustainability due diligence starts now, published in the August 2024 issue of AB.

• Exempt importers of small quantities of CBAM goods.
• Simplify the authorization of declarants, the calculation of emissions, and the management of financial liability.
• Strengthen the anti-abuse provisions and develop a joint anti-circumvention strategy.

Further details can be found in the EU CBAM Proposal: Key Changes and Implications article by Anthesis.

^{3.     BSR_Omnibus_FactSheet_Mar2025.pdf}

• Increase EU guarantee.
• Simplify the reporting requirements.
• Enhance access for SMEs.
• Integrate with legacy programs.

^{4.     Simplifying investment: Council agrees its position on the InvestEU regulation to boost the EU's competitiveness - Consilium}

• Limit obligations to largest companies, with possibility for others to report voluntarily. 
• Those in-scope and voluntary reporters are required to disclose turnover and CapEx Key Performance Indicators  (KPIs) and may choose to disclose their OpEx KPI.
• Report on activities that might be partially taxonomy aligned.
• Simplify reporting templates, reduce data points.
• Exempt from taxonomy assessments if below certain turnover, capital expenditure or total assets thresholds. 
• Simplify the most complex 'Do No Significant Harm' criteria for pollution prevention and controls related to the use and presence of chemicals.

Further details can be found in the ESG – Commission proposes changes to Taxonomy Regulation Level 2 article by simmons+simmons. 

^{5.     How to navigate the EU Omnibus Simplification Package}

In April 2025, the 'stop-the-clock' proposal, ie the delayed reporting for CSRD and CSDDD, was approved. EU Member States have until 31 December 2025 to transpose it into national law, although some countries have already done so.^{6 7}

Also in April 2025, the EC formally mandated the EFRAG to revise the ESRS in line with the Omnibus Package. A public consultation to gather feedback on the revision of ESRS set 1 was open until 6 May. A consultation on the simplified ESRS exposure drafts opened in July and runs until 29 September 2025.⁸ EFRAG has also launched a cost-benefit analysis study, taking place between July and December 2025, on the proposed simplification to the ESRS⁹. EFRAG is expected to deliver its technical advice to EC on the updated ESRS by 30 November 2025.¹⁰

Read ACCA’s response to the ESRS set 1 revision consultation, calling for a simplification of the ESRS and greater alignment with the IFRS Sustainability Disclosure Standards.

In June 2025, the Council agreed its position on some of the broader amendments to CSRD and CSDDD, beyond 'stop-the-clock' For CSRD, the Council’s position includes a further reduction in scope but with the addition of a review clause to extend the scope if required. For CSDDD, the Council’s mandate includes a reduction of those in scope by increasing thresholds, a change to a risk-based approach when looking at the value chain, a simplification and delay of implementation of the transition plan provisions and a one year postponement of the transposition deadline¹¹. The proposed amendments to CSRD and CSDDD still need to go through further negotiations and voting. It is unlikely that agreement will be reached before 2026.¹²

In July 2025, the EC adopted a 'quick fix' delegated act with targeted amendments to the first set of ESRS. The modifications, for those that have already started reporting, allow the omission of anticipated financial effects until FY 2027 and other data points (depending on the size of the organization).¹³ The European Parliament and Council have two months (with potential to extend by a further two months) to scrutinise the delegated act but have been urged by some associations, including Accountancy Europe, not to object.¹⁴

The EC intends to issue a recommendation on voluntary sustainability reporting as soon as possible, based on the VSME standard developed by EFRAG.¹⁵ The EC adopted the VSME as a recommendation in July 2025.¹⁶

Read ACCA’s responses to the consultation on VSME from May 2024.

The EC plans to issue targeted assurance guidelines before adopting limited assurance standards (expected by October 2026); these guidelines will provide companies with clearer expectations for sustainability reporting.¹⁷

^{6.     Newsflash | 'Stop the Clock' Directive: Luxembourg implementation of CSRD
7.     EU Omnibus Update – Recent Developments relating to CSRD and CSDDD – 'quick fix' and more
8.     Extended Duration of EFRAG’s Public Consultation on ESRS Simplification | EFRAG
9.     Survey on Cost-Benefit Analysis of Simplified ESRS | EFRAG
10.   Press release - EFRAG Shares Revised ESRS Exposure Drafts and Launches 60-Day Public Consultation | EFRAG
11.   Simplification: Council agrees position on sustainability reporting and due diligence requirements to boost EU competitiveness - Consilium
12.   EU Omnibus explained
13.   Commission adopts 'quick fix' for companies already conducting corporate sustainability reporting - European Commission
14.   Joint call: swift adoption of the 'quick-fix' delegated act - Accountancy Europe
15.   QANDA_25_615_EN.pdf
16.   Commission presents voluntary sustainability reporting standard to ease burden on SMEs
17.   Impacts for US Companies of the Proposed EU Omnibus Package}

The Council¹⁸ and Parliament¹⁹ have reached a provisional agreement on the CBAM proposals from the Omnibus Package. The proposals will now be formally endorsed by the Council and Parliament with final adoption expected by September 2025.20

A full review of CBAM will be completed in 2025 to assess its potential extension to other Emissions Trading Scheme (ETS) sectors, downstream goods, indirect emissions. The EC will also examine how to help exporters of CBAM products at risk of carbon leakage. This will be followed by a legislative proposal in early 2026.²¹

^{18.   Simplifying EU’s carbon border adjustment mechanism: Council agrees negotiating position - Consilium
19.   European Parliament approves simplifications to CBAM procedures suggested by European Commission
20.   Carbon border adjustment mechanism (CBAM): Council and Parliament strike a deal on its simplification - Consilium
21.   Q&A on simplification omnibus I and II}

In April 2025, member states’ representatives endorsed the Council’s position on the InvestEU proposals. The proposal will now go to interinstitutional negotiations, with the view to reaching a provisional agreement with the European Parliament.²²

^{22.   Simplifying investment: Council agrees its position on the InvestEU regulation to boost the EU's competitiveness - Consilium}

The amendments to the EU Taxonomy, were open to public consultation until 26 March 2025²³. In July 2025, the Delegated Act amending the Taxonomy Disclosures, Climate and Environmental Delegated Acts was adopted by the EC. The Delegated Act is currently being scrutinised by the European Parliament and the Council. The simplification measures laid out in the Delegated Act will apply as of 1 January 2026 and will cover the 2025 financial year.²⁴

^{23.   ESG – Commission proposes changes to Taxonomy Regulation Level 2 | Simmons & Simmons
24.   Commission to cut EU taxonomy red tape for companies - European Commission}

In July, the EU’s Ombudsman formally challenged the EC on why standard regulatory procedures were bypassed and the Omnibus Package proposals were fast-tracked. This was in response to complaints by campaigners that rules are being weakened with inadequate broad public consultation and insufficient assessment of their impact. The EU Commissions had until 15 September 2025 to respond.^{25 26}

^{25.   EU Commission faces complaint over easing of sustainability rules | Reuters
26.   Watchdog demands EU explain speed of proposals to cut green rules | Reuters}

Some reporting deadlines have been delayed, giving companies more time to prepare. This should help to ease short-term pressure and free capacity to build reporting systems and improve data quality in anticipation of future reporting.

The amount of information that can be requested from companies out of scope should be capped and guided by a voluntary standard, based on the VSME. This prevents those out of scope being inundated with extensive information requests in multiple different formats.

Thresholds should help companies to concentrate and focus efforts on the most significant areas.

Simplified and streamlined requirements and clarity should enhance consistency and comparability of reports.

Reducing the reporting complexity and compliance burden should help enable internal capacity to foster innovation in sustainable practices. 

Simplified administrative requirements should increase the accessibility of funding and the increased guarantee should mean there is more funding available.

Delay transition towards sustainable business models – some companies may view the reduction in scope and delay in timing as an excuse to pause sustainable action. The removal of the requirement to ‘put into effect’ a transition plan reduces the accountability and legal force for executing a plan. This could delay the net-zero, nature-positive and just transition.

It may be more challenging to identify and address violations which could allow continued unethical practices and environmental harm in the value chain.

The narrower definition of stakeholder could reduce the diversity of perspectives gathered when completing due diligence. 

If disclosure is reduced or delayed investors could have insufficient information to make capital allocation decisions based on progress on sustainability.

^{27.     How to navigate the EU Omnibus Simplification Package}

In the absence of sector-specific guidance reporting may be less meaningful and companies may struggle to interpret and apply general standards to their business.

A delay in companies reporting on their sustainability credentials prevent them from accessing certain sources of sustainable finance.  

The information that large companies can request from those out of scope is limited by the content of a voluntary standard.²⁸ This reduces the administrative load for SMEs (as there is a cap on what large companies can request) and increases efficiencies as there is one standardized framework that everyone is encouraged to use.

^{28.     Unless additional information is needed to carry out mapping and the information cannot be obtained in any other reasonable way.}

EU-listed SMEs were previously required to report using the LSME, this has been removed under the Omnibus Package proposals. EU-listed SMEs may choose to voluntary opt-in and report. This liberates EU-listed SMEs from reporting requirements while still allowing them to engage with voluntary sustainability reporting if they wish to. 

The delayed reporting of those in-scope for CSRD, who have not yet started reporting, may trickle down to SMEs providing more time to prepare for such information requests.

The shift to monitoring every five years means that SMEs may face fewer requests and less frequent engagement. Additionally, by limiting due diligence obligations to direct business partners or taking a risk-based approach, SMEs may be excluded from these requirements altogether, reducing their overall compliance burden.

Most SMEs that import only small amounts of carbon-intensive goods will likely fall below the reporting threshold, meaning they can avoid the costly burden of collecting emissions data, calculating carbon output, and purchasing CBAM certificates.

InvestEU and other EU-backed financial instruments will have simplified reporting requirements and less bureaucracy, which may make it easier for SMEs to access EU funding and guarantees.