European Parliament adopts position on proposed Omnibus Directive

On 13 November 2025 the European Parliament adopted its negotiating position on the proposed directive amending the EU Corporate Sustainability Reporting Directive ("CSRD") and the EU Corporate Sustainability Due Diligence Directive ("CSDDD"), which forms part of the Omnibus I Package (the “Omnibus”).

Some of the key details of the European Parliament's proposal are set out below (in comparison to the other EU institutions and the current text of the Directives). 

The European Parliament's proposal also includes other significant changes to CSDDD:

• Deletion of requirement to have a transition plan from CSDDD (whilst the requirement to disclose on existing transition plans remain in CSRD). 
• Requiring in-scope companies to take a risk-based approach to identifying and assessing adverse impacts, relying on information which is already available and only requesting additional information from their smaller suppliers as a last resort. 
• Removal of the specific EU-wide civil penalty provisions, keeping civil liability only at the national level. 

The three EU institutions will now move to trilogue negotiations on 18 November 2025, which will involve a limited number of representatives from the European Commission, the European Parliament, and the Council of the European Union. These informal negotiations aim to reconcile differing views and priorities and expedite the legislative process, with the hopes of finalising the negotiations by the end of the year.

Additional Omnibus updates

• In addition, the 'Quick Fix' Delegated Regulation was published in the Official Journal of the EU on 10 November 2025, extending phase-in provisions under the current European Sustainability Reporting Standards (ESRS) for companies who have already been required to start reporting under CSRD ("Wave 1 Companies").  
  The Delegated Regulation applies retrospectively from 1 January 2025 and will allow Wave 1 Companies to continue taking advantage of various phase-in provisions and transitional relief measures for reporting years 2025 and 2026.  As a result, Wave 1 companies will not be required to report additional information for those two years beyond what was included in their 2024 reports, to alleviate the burden of reporting as these Wave 1 Companies are not caught by the 'Stop-the-Clock Directive'. That Directive delayed the application of CSRD for companies in scope of CSRD within the waves after Wave 1 (see our briefing on the 'Stop-the-Clock Directive' here).
• Finally, EFRAG has announced it will release its Draft Simplified ESRS on 4 December 2025, which will follow EFRAG's technical advice to the Commission which is due to be provided on 30 November 2025. These Simplified ESRS will then need to be adopted by the Commission before entering into force.