Sustainability didn’t begin with the European Green Deal. Europe has long outlawed slavery, child labour, pollution violations, bribery, corruption, practices universally recognised as unacceptable. The Omnibus package released in early 2025 doesn’t change that baseline. Instead, it refocuses on core sustainability requirements already embraced by regulators and stakeholders.
CSRD
- Omnibus status: Still a proposal as of May 2025. Meanwhile, EU "stop-the-clock" rules delay CSRD rollouts for Waves 2 and 3 until 2028
- Scope remains: It still applies to companies with over 1,000 employees and >€50 m revenue or >€25 m balance sheet — simplification won’t alter that in 2025
- Double Materiality stays intact and ESRS disclosures remain mandatory
- Sector‑specific ESRS launch is postponed as simplification progresses
EU Taxonomy
- Opt‑in model: Companies in scope of CSRD with <€450 m turnover now have an option—not obligation—to report Taxonomy alignment under the Omnibus proposal
- Must demonstrate alignment if claiming sustainable activities, ensuring transparency on green claims
- KPIs simplified: Turnover and CapEx remain required; OpEx is now voluntary
- DNSH criteria simplified to reduce complexity
CSDDD
- Tier 1 obligations remain firmly in place.
- Downstream due diligence only required when there are identified risks.
- Own operations compliance is unaffected.
- Implementation delayed: Companies must comply by July 2028 — a one-year postponement
National Legislation
Norwegian Transparency Act (åpenhetsloven)
- Still in full force: applies annually to medium and large Norwegian companies.
- Enforcement remains active under the Norwegian Consumer Authority.
German Supply Chain Act (LkSG)
- Still legally valid in 2025, applying to companies with over 1,000 employees since 2024
- A potential replacement is under consideration by Germany’s new coalition (Spring 2025), aiming to align with CSDDD. If adopted, it would cancel and replace LkSG, with enforcement paused until the EU-aligned law is in effect (delayed post-2028)
Swiss VSoTR
- Still active: applicable since January 2022 to companies sourcing minerals from high-risk areas. No major updates in 2025.
What comes next?
Even as Omnibus reduces reporting burdens on paper, the fundamentals of supply chain sustainability remain unchanged. Companies must still:
- Map and assess supplier risk
- Follow a due-diligence process (incl. Tier 2+ if triggers arise)
- Maintain grievance mechanisms
- Report transparently under CSRD
- Align or opt into Taxonomy where relevant
Factlines helps you stay ahead, avoiding missing data, reputational risks, procurement disqualification, or funding barriers.
Do you have questions about how the Omnibus proposal might impact your business? Contact us to discuss what these changes mean for your reporting and compliance strategy.
