The European Parliament’s position on the Omnibus I proposal

Following the Draghi report on European Union competitiveness, the European Commission proposed in February 2025 to significantly reduce regulatory burdens for European entities by bringing material changes to sustainability-related regulations, particularly CSRD, CS3D and the Taxonomy Regulation. In this context, on 13 November 2025, the European Parliament adopted its negotiating position on simplifying companies’ sustainability reporting and due diligence obligations, with 382 votes in favour, 249 against, and 13 abstentions.

What are the main modifications proposed by the European Parliament?

CSRD

• Thresholds: only companies employing an average of 1,750 employees and generating more than EUR450 million in net turnover remain within the scope of the regulation. The European Parliament’s position is more lenient than that of the European Council, which had set the threshold at 1,000 employees.
• Value chain cap: In-scope companies should only request information from business partners when strictly necessary. For partners with fewer than 5,000 employees, such requests are allowed only as a last resort if the data cannot be obtained from other sources and must remain targeted and proportionate.

CS3D

• Thresholds: only companies employing an average of 5,000 employees and generating more than EUR1.5 billion in net turnover remain within the scope of the regulation.
• Civil liability: the EU-wide regime on civil liability is deleted, which implies that Member States will have to manage violations to obligations stemming from CS3D through their own legal systems.
• Due diligence: a new fully risk-based approach to due diligence. This point will require further negotiations with the European Council, which favours a different model focused on own operations and main business partners.
• Transition plans: in-scope entities are no longer required to develop a transition plan aligned with the Paris Agreement.

Digital portal: the European Parliament called for the European Commission to launch a free digital portal as a one-stop shop, providing templates, guidelines, and information on European reporting requirements (including those related to CSRD and to CS3D), as well as funding opportunities to support compliance with due diligence obligations.

What’s next?

The trilogue is scheduled to begin on 18 November 2025. While certain points still require negotiation, rapporteur Jörgen Warborn emphasised that, given the ‘Stop-the-Clock’ timeline and the need for predictability for companies, the legislation should be finalised by the end of 2025.

As a reminder, the ‘Stop the Clock Directive’ has postponed by two years the reporting requirements for companies currently in the scope of CSRD (except for non-EU parent companies), with the first CSRD reports now due between 2028 and 2029 instead of 2026–2027. Concerning CS3D, the deadline for transposition into national law is 26 July 2027, and the first wave of in-scope companies will have to comply starting on 26 July 2028.