Omnibus is rolling

On December 16, 2025, the European Parliament adopted the so-called "content proposal" to amend the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). In future, significantly fewer companies will fall within the scope of both directives. The implementation of the CSRD planned in Germany by the end of this year is off the table. This means that the old sustainability reporting regulations will continue to apply.

At EU level, there have been some changes in terms of simplifying sustainability reporting: Under the amendment directive, companies will only be subject to reporting requirements in the future if they employ more than 1,000 people on average over the year and generate revenues of more than EUR 450 million in the respective financial year. The new thresholds apply to financial years beginning on or after January 1, 2027.

For companies in the so-called "Wave 1," which were or would have been subject to reporting requirements up to now but will no longer fall under the CSRD in the future, the amending directive provides for an option for member states. According to this, they can exempt the companies concerned from reporting requirements for the 2025 and 2026 fiscal years. The German legislature had already anticipated this in its government draft published in September and provided for a corresponding exemption. The implementation law was scheduled to be passed by the end of the year, but this will no longer happen. Therefore, there is generally no reporting obligation under the CSRD for the 2025 financial year in Germany.

The sector-specific reporting requirements previously provided for under the CSRD will become voluntary with the amendment directive.

The scope of application of the CSDDD is also significantly narrowed. It now only applies to companies with more than 5,000 employees and net sales of more than EUR 1.5 billion. In addition, there are also changes to the content: for example, the previously planned obligation to draw up a plan to mitigate the effects of climate change has been dropped. The deadline for transposing the CSDDD into national law has been postponed to July 2028. Companies will then have to apply the new rules from 2029 onwards.

The Council of the European Union has yet to formally approve the amending directive. It will enter into force on the 20th day after its publication in the Official Journal of the European Union, which is expected in March 2026. Member states will then have one year to transpose the amended requirements into national law.