- On 13 November, the EU Parliament voted to approve the Legal Affairs Committee’s proposal on the Corporate Sustainability Due Diligence Directive (CSDDD) and Corporate Sustainability Reporting Directive (CSRD) Omnibus after it was previously rejected by Parliament on 22 October.
- As with the previous draft and the Commission’s proposal, the changes are mainly to scope and thresholds. There is very little that materially alters the due diligence requirements for companies subject to the CSDDD and CSRD.
- Trilogue started on 18 November 2025 and aims to finish by the end of the year.
Key Changes
- CSRD
- Scope narrowed – Only large companies with over 1,750 employees and €450 million turnover will be required to conduct sustainability reporting.
- Simplified European Sustainability Reporting Standards (ESRS) – Reporting obligations will be simplified, sector-specific reporting will be optional, and smaller companies will be shielded from additional data requests by larger partners. These additions are largely in line with the changes proposed by the European Commission which also recommended a reduction in scope of the ESRS, removal of sector-specific ESRS and protections for smaller suppliers.
- CSDDD
- Scope narrowed: Only large companies with 5000 employees and €1.5 billion in turnover will be required to comply.
- Climate transition plans removed: Climate change transition plans and their guidance have been deleted from the text. Companies would not need to issue plans under the CSDDD, but they continue to be required under the CSRD and other EU legislation.
- Removal of EU-wide civil liability: EU-wide civil liability has been removed, and no review clause has been added. This will mean civil liability will have to be brought through courts in the national member states, rather than at the EU level.
- Due diligence kept risk based: A full risk-based approach to due diligence with a value-chain cap. This differs from the Commission which called for identification of impacts only for direct business partners and indirect only when plausible information exists.
- Information cap: In-scope companies should rely on information already available and request additional information from their smaller business partners as a last resort.