Update: 20 November 2025
EU Omnibus: The 'trilogue black box.'
Here’s how it works.
With Parliament’s Omnibus position now adopted, we move into the next phase: trilogues. The EU’s three-way negotiations to agree the final law.
Three players are at the table:
- European Commission – proposed the Omnibus to simplify, raising CSRD scope to >1,000 employees + €450m turnover and easing some CSDDD duties.
- Council (Member States) – broadly backed that line in June, keeping the 1,000 + €450m CSRD test and pushing for lighter obligations and earlier exits for some reporters.
- Parliament – went further in November: CSRD only for >1,750 employees + €450m, cutting scope by ~90%+, and CSDDD only for 5,000 employees + €1.5bn turnover (or €1.5bn EU turnover for non-EU groups).
How trilogues work:
1. Each institution has its mandate. Commission (proposal), Council (June mandate), Parliament (13 Nov vote).
2️. Small teams negotiate behind closed doors, going article by article; thresholds, timelines, definitions, enforcement.
3. Once there’s a compromise text, lawyers tidy it up and both Parliament (plenary) and Council (Member States) must formally approve it.
Where could Omnibus land? Very roughly, three paths:
- Council-leaning deal. CSRD thresholds closer to 1,000 + €450m, CSDDD thresholds stay high, some simplifications survive.
- Parliament-leaning simplification. 1,750 + €450m CSRD and very narrow CSDDD, focused almost entirely on the top tier of multinationals.
- Hybrid “re-balancing”. Some re-tightening (e.g. on climate plans or value-chain reach) while still delivering a visible cut in the number of in-scope companies.
What should companies do now?
✅ Plan for a range, not a single number – test your CSRD/CSDDD exposure under Commission, Council and Parliament thresholds.
✅ Anchor in strategy, not just compliance – assume investors, banks and key customers will still expect decision-useful sustainability data, even if you drop out of the legal perimeter.
✅ Use the trilogue window to educate your board – on what each scenario would mean for governance, data, assurance and capital allocation.
The trilogue may change the shape of CSRD and CSDDD, but it won’t change the direction of travel: credible, decision-useful sustainability information is only getting more important.
Update: 19 November 2025
Non-EU groups & the EU Omnibus: fewer caught, higher expectations if you are
The Omnibus vote in the EU Parliament on 13 November doesn’t just narrow CSRD for EU companies — it also reshapes the picture for non-EU groups with EU subsidiaries or branches.
Scope under Parliament’s position
A non-EU group must prepare a CSRD-style sustainability report for the whole group only if it has:
- An EU subsidiary with more than €450m net turnover, or
- An EU branch with more than €450m net turnover (previous year)
Key implications
- The earlier focus on aggregate EU turnover at group level is effectively gone.
- Groups with many mid-sized EU entities are now far less likely to be in scope.
- Groups with one very large EU hub (over €450m) remain firmly in scope.
Where does NESRS fit in?
CSRD still expects dedicated reporting standards for third-country undertakings (NESRS). On paper, the Wave 4 timeline remains:
- Reporting on FY 2028
- First NESRS/CSRD-style reports in 2029
While timing could shift politically, this points to a delay and simplification — not a repeal.
Recommended actions for non-EU HQs
- Map your EU footprint by entity and identify which are at or near €450m — this is now the true trigger.
- Use ESRS or draft NESRS as your design blueprint; build governance, data, and controls around that structure.
- Plan for timing uncertainty while continuing to prepare; aim to be refining rather than scrambling if Wave 4 lands in 2029.
Bottom line
The Omnibus means fewer non-EU groups will formally fall under CSRD/NESRS, but those that do will face higher expectations — and will be expected to set the global benchmark for sustainability reporting in their sector.
Update: 18 November 2025
EU Omnibus: CSRD & CSDDD just got cut down and a lot narrower. Now what?
On 13 November, the European Parliament adopted its final position on the Omnibus, dramatically reshaping the EU’s sustainability framework.
CSRD changes
Parliament proposes restricting mandatory CSRD reporting to companies with:
- More than 1,750 employees, and
- More than €450m net turnover
This is a major shift from the original “large company” test (250 employees + €50m turnover / €25m balance sheet). The change is expected to reduce the number of companies in scope from around 50,000 to roughly 3,000–5,000 — a 90–92% reduction.
CSDDD changes
Parliament’s position also narrows the CSDDD scope:
- Focuses on only the very largest players
- Increases employee and turnover thresholds (particularly for non-EU groups)
- Removes several ambitious elements, including mandatory climate transition plans and a harmonised civil-liability regime
The Directive shifts toward a narrower, risk-based due diligence tool.
What should companies actually do now?
If you are clearly still in CSRD scope
Treat the changes as breathing space, not a signal to slow down.
- Assume full CSRD + ESRS (including sector standards over time) will still apply.
- Use the simplification debate to refocus on data quality, internal controls, and governance rather than chasing every disclosure checkbox.
- Strengthen your value-chain and data-collection strategy so requests to suppliers and subsidiaries remain proportionate and decision-useful.
If you are likely to fall out of CSRD scope
Don’t halt momentum simply because the legal obligation may disappear.
- Investments in double materiality, stakeholder engagement, and metrics are strategic assets, not sunk costs.
- Reframe your CSRD work as part of your sustainability performance and investor narrative. You can continue reporting in a lighter, more focused format that still meets expectations from banks, investors, and major customers.
- Consider adopting a CSRD-inspired but right-sized framework — using ESRS for structure while reducing depth where appropriate.
If you never started CSRD preparation
This is not a “get out of sustainability free” moment.
- Banks, investors, and large customers will continue to expect credible, comparable sustainability information, even without a legal ESRS obligation.
- Use this moment to design a lean, strategy-led framework drawing on CSRD, ISSB, and GRI that fits your size and risk profile.
- Evaluate the VSME standard: the Commission has highlighted it as a practical option for companies outside CSRD scope, and it will likely influence future voluntary EU standards and expectations within value chains.
Important caveat
This is only the European Parliament’s position. The Omnibus now enters trilogue negotiations with the Council and Commission, where thresholds and technical details may still change.
More insights coming soon as trilogue discussions progress.
