05/16/2025

EU Omnibus 2025 – What is to change in CSRD, CSDDD, Taxonomy, CBAM & InvestEU

For years, companies have been complaining about the high bureaucratic hurdles surrounding sustainability obligations – not only large corporations, but also SMEs in particular. The EU has responded: With the Omnibus Package 2025, it is putting key regulations to the test – and changing sustainability reporting (CSRD), due diligence obligations (CSDDD), the EU taxonomy, the carbon border adjustment mechanism (CBAM) and the InvestEU funding program, among other things.

According to the Commission, the aim is to simplify, reduce burdens and promote investment – without abandoning the climate targets.

We have summarized the specific changes for you in a compact and well-founded way.

CSRD – Sustainability reporting

The CSRD came into force in 2023 and is set to gradually oblige almost 50,000 companies in the EU to report on ESG. Many companies had already made preparations – but are now backpedaling.

What will change in concrete terms?

New area of application:

Only companies with more than 1,000 employees and
over € 50 million in turnover or € 25 million in total assets
➜ This reduces the group of companies subject to reporting requirements by around 80%

Postponement of the reporting obligation:

Wave 2 (large companies): from 2028
Wave 3 (listed SMEs): from 2029

Further simplifications:

Abolition of sector-specific ESRS standards
No transition to “reasonable assurance”
Revision of the existing ESRS to reduce data points
VSME standard (voluntary report for small and medium-sized companies, as protection against excessive requests from larger customers)

📌 What does that mean?
Many companies that have already begun implementation can breathe a sigh of relief – but should not throw existing structures overboard, but rather streamline them in a targeted manner.

CSDDD – Due diligence obligations in supply chains

The Corporate Sustainability Due Diligence Directive (CSDDD) affects large companies with complex supply chains. Originally intended as a strongly regulating counterpart to the German LkSG, it is now more pragmatic.

What will change in concrete terms?

Introduction postponed:
Transposition into national law by July 2027
First application (largest companies): from July 2028
Focus on direct business partners:
➜ Indirect partners only in case of concrete suspicion or relevant information
Evaluation only every five years (instead of annually)
Civil liability is regulated nationally
➜ No more EU-wide uniform liability regulations
Information requirements for SMEs limited:
➜ Large companies may only request information that is provided for in the VSME standard

📌 What does that mean?
The directive is becoming more manageable – and not only relieves the burden on large companies, but above all their smaller partners in the supply chain.

EU taxonomy – less obligation, more clarity?

The taxonomy is the EU’s instrument for objectively defining “green” economic activities. In practice, however, it has caused confusion and additional work – especially for companies that are only partially affected.

What will change in concrete terms?

Mandatory reporting only for very large companies:
➜ Companies with >1,000 employees AND >€ 450 million turnover
Economically immaterial activities (<10% turnover, CapEx):
➜ No obligation to evaluate or report
Partial conformity is permitted:
➜ Companies may voluntarily report progress on sustainable activities, even if full compliance has not yet been achieved
Standardization & relief:
Reduction of data points by up to 70%
Improvements to the green asset ratio for banks
DNSH criteria to be simplified and made more practicable

📌 What does that mean?
For many companies, taxonomy is becoming a much smaller issue – unless they want to actively finance or position themselves sustainably.

CBAM – CO₂ boundary balancing system

CBAM is the EU’s attempt to prevent “carbon leakage” – the migration of CO₂-intensive production to third countries. The rules are complex, but the omnibus package brings real simplifications.

What will change in concrete terms?

Introduction of a threshold value:
➜ CBAM only applies to imports of more than 50 tons of CBAM goods per year
➜ This exempts 90 % of importers, but 99 % of emissions are still covered
Further facilitations:
Standardized CO₂ values from 2027
Simplification of emissions calculations
Simplification of approval and reporting

📌 What does that mean?
Smaller and occasional importers in particular can breathe a sigh of relief. Those who are still affected will benefit from clearer processes.

InvestEU – Funding program for sustainability

I nvestEU is the major EU funding instrument for supporting innovation, infrastructure and sustainability. Here, too, bureaucracy is being cut.

What will change in concrete terms?

Fewer reporting obligations:
➜ For final recipients (especially SMEs), intermediaries and implementation partners
Simpler application of the SME definition
➜ Fewer hurdles for small transactions
Effect:
➜ 350 million in administrative cost savings
➜ Potential to mobilize € 50 billion in investments

📌 What does that mean?
Funding applications and processing will be streamlined – particularly relevant for smaller companies with sustainable projects.

Conclusion: Relief with a sense of proportion – don’t cut everything now

The omnibus package brings noticeable relief, especially for small and medium-sized companies. At the same time, the basic requirements remain in place – partly postponed, partly voluntary, but still effective.

📌 Our recommendation: