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Q&A - The EU Omnibus Package

Read about the EU Omnibus Package and its current status including why the package is needed and what it includes as well as how you can prepare.
The EU Omnibus Package is continually evolving, the information on this page was last updated on 5 February 2026. However, we expect this to be an iterative process and future updates will be made to the information on this page.

    Why is the Omnibus Package needed and what does it include?

    The EU wishes to boost its competitiveness and growth, encourage innovation and economic resilience and foster transparency and trust. One key strategy to achieve this is by removing excessive regulatory burdens.1

    The European Commission (EC) has a target to achieve 'at least 25% reduction in administrative burdens and at least 35% for SMEs' before the end of 2029. To help realise this ambition the EC is delivering a programme of Omnibus packages.2

    The first and second Omnibus simplification packages (the Omnibus Package) were published on 26 February 2025 and include proposed amendments to the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), the Carbon Adjustment Mechanism (CBAM) and the InvestEU Regulation. A draft Taxonomy Delegated Act (DA) was also released alongside the Omnibus Package.2

    The Omnibus Package includes measures to simplify requirements, increase alignment, reduce the number of companies in scope and delay some reporting timelines.

      What is ACCA doing to engage on the Omnibus Package?

      ACCA has already released, or is in the process of drafting, content relevant to the Omnibus Package, including:

      ACCA is monitoring the developments of the Omnibus Package and, if appropriate, will submit consultation responses. As evidenced above, ACCA also regularly engages with Accountancy Europe, EFAA and smeunited on their positions and may submit collaborative consultation responses. 

        What are the key proposed changes?

        The key proposed changes, outlined in the Omnibus Package published on 26 February, were:

          • 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.

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

          • 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. 

          What has already been agreed and what is next?

          The various elements of the Omnibus Package have been progressing through negotiation and approval at different rates, their status, as of 4 February 2026, is summarised in the table below.

            • In April 2025, the 'stop-the-clock' proposal, ie the delayed reporting for CSRD and CSDDD, was approved. EU Member States had until 31 December 2025 to transpose it into national law.6 7
            • In July 2025, the EC adopted a 'quick fix' DA 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)8. The 'quick fix' DA was published in the Official Journal of the European Union (OJEU) and entered force on 13 November 2025.
            • 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 2025. A consultation on the revised ESRS exposure drafts was open from 31 July until 29 September 2025.9 EFRAG delivered its technical advice to EC on the updated ESRS on 3 December 2025.10 The EC will now prepare the DA revising the first set of ESRS based on EFRAG’s technical advice. The EC aims to adopt the amended ESRS DA by mid-2026 depending on the Omnibus legislative developments. In December 2025, the ESRS Knowledge Hub was launched, it contains the draft standards as well as implementation guidance.

            ACCA’s responses to the ESRS set 1 revision consultation and the ESRS exposure drafts encouraged the 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'. The amendments to CSRD and CSDDD went much further than the initial proposals, resulting in greater reductions in the number of companies covered by each regulation. These amendments have now been approved and the final text will be published in the OJEU and will enter force 20 days after publication and Member States will then have 12 months to transpose the amendments into national law.11 The final agreed key amendments are as follows12 13: 

            CSRD

            • in-scope EU entities are those with an average of more than 1,000 employees during the financial year and a net turnover exceeding €450 million14 and non-EU entities generating a net turnover in the EU of €450 million for each of the last two consecutive financial years and that have an EU subsidiary or branch generating more than €200 million in EU net turnover.
            • reporting entities are not permitted to request information from out of scope value chain entities that exceeds the content of the voluntary sustainability reporting standards. 
            • a digital portal will be established where undertakings can access templates and guidance and support on EU and national reporting requirements.
            • the obligation to adopt delegated acts to provide limited assurance standards is no later than 1 July 2027.

            CSDDD

            • applies to EU entities with more than 5,000 employees and net turnover exceeding €1.5 billion and non-EU entities with a €1.5 billion turnover in the EU in the financial year preceding the last financial year
            • adoption of a risk-based approach rather than prescriptive value-chain mapping obligations
            • removal of the obligation to adopt and implement a climate transition plan 
            • member States shall adopt and publish the laws, regulations and administrative provisions necessary to comply with CSDDD by 26 July 2028 and measures shall be applied by 26 July 2029
            • the EC should publish due diligence guidelines by 26 July 202715 16
            • The EC adopted the VSME as a recommendation in July 202517. Whether changes are required to the VSME in developing the content of the future voluntary reporting standard will depend on the final agreement on the scope of application of sustainability reporting requirements and on the revision of the ESRS18. ACCA’s responses to the consultation on VSME in May 2024 can be found here. 

            • On 29 September 2025, the Council adopted the regulation for the CBAM proposals from the Omnibus Package. The CBAM legislative act was published in the OJEU on 17 October 2025 and entered into force on the third day following publication, ie 20 October 2025.19 20 21  
            • A full review of CBAM is taking place to assess its potential extension to other Emissions Trading Scheme (ETS) sectors, downstream goods, indirect emissions. On 17 December 2025, the EC published a legislative proposal to amend the existing CBAM regulation to extend CBAM’s scope to downstream goods and to introduce anti-circumvention measures.22

            In September 2025, the Council presidency and the European Parliament’s negotiators reached a provisional agreement to simplify the InvestEU programme.23 The revised regulation was signed off by the Council on 11 December 2025. The legislative act was published in the OJEU on 23 December 2025 and entered force the day after.24

            The amendments to the EU Taxonomy, were open to public consultation until 26 March 2025.25 In July 2025, the DA amending the Taxonomy Disclosures, Climate and Environmental DAs was adopted by the EC. On 8 January 2026, the revised DA was published in the OJEU. 

            In May 2025, the EU’s Ombudswoman opened an official enquiry into the EC on why standard regulatory procedures were bypassed and the Omnibus Package proposals were fast-tracked26. 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 European Ombudswoman found a number of procedural shortcomings in the EC’s urgent preparation of several proposals, notably the Omnibus I on sustainability. EC responded to the inquiry in September 202527. The Ombudswoman published a report in November 2025 concluding that there were procedural shortcomings which taken together amount to maladministration.28 29

            What are the potential benefits and risks?

            The potential benefits include:

            Some companies are no longer in scope. For those that remain in scope, the requirements are being simplified and streamlined and the number of datapoints reduced. This should relieve the compliance burden and alleviate the strain on resources.

            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.

            The potential risks include:

            Some companies may view the reduction in scope and delay in timing as an excuse to pause sustainable action. The removal of the transition plan requirements under CSDDD 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.

            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.  

            What will be the main benefits for SMEs?

            The information that large companies can request from those out of scope is limited by the content of a voluntary standard.31 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.

            31.     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 voluntarily 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 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.

            How can you prepare?

            Now many of the amendments under the Omnibus Package have been debated and finalised, taking action now to prepare is important - whether the company is in or out of scope or inside or outside the EU. In-scope companies must meet requirements, possibly with extended deadlines, while out-of-scope companies will likely face information requests from partners. Proactive preparation helps maintain competitiveness, prevent supply chain issues, and meet stakeholder expectations. To prepare, it may be helpful to: 

            Stay informedMonitor the latest developments on the Omnibus Package as they are being negotiated, finalized, approved and enforced.
            Engage with policymakersCommunicate with those making the decisions, either directly or via industry groups. Share your views on the proposals and exposure drafts.
            Assess applicabilityEvaluate whether you are in or out of scope. If out of scope, consider the potential of trickle down requirements from customers and those in your value chain.
            Connect with business customersCommunicate with your business customers to understand the impact of the Omnibus Package on them and their expectations from you in relation to requests for sustainability information.
            Evaluate the potential impact of the proposed changesAssess the implications of the proposed changes on your organization (either directly or indirectly).
            Consider voluntary reportingIf you're not required to report, consider doing so voluntarily. Voluntary reporting can help you meet the expectations of investors, stakeholders and those in your value chain.
            Prepare for reportingStart preparing now — or continue building on your current efforts — meeting the requirements can be time-consuming. Beginning early increases your chances of staying on track and meeting deadlines, even if the deadlines have been delayed.
            Progress sustainabilityBegin—or continue—assessing your sustainability impacts, risks, and opportunities, and integrate these into your strategy and governance. This will help you go beyond just meeting regulations and position your organization to take advantage of sustainability-related opportunities.
            Strengthen internal processesEnhance your internal controls, governance structures, compliance processes, due diligence, and stakeholder engagement practices to better integrate sustainability. Focus on improving the quality of your sustainability data, incorporate sustainability-related risks into your overall risk management systems, and establish clear frameworks and action plans to guide your efforts.
            Improve data qualityPrioritize the key data points required and work on improving their quality. This will support better decision-making and enhance the accuracy and reliability of your sustainability reports.
            Align with othersReview the action and disclosures being made by your competitors and others in your sectors, use this to inform your own work.

            EY’s guidance on How to navigate the EU Omnibus Simplification Package provides useful insights on how you can prepare.