From Draft To Reality: How The Omnibus Alters CSRD And CSDDD – Corporate Governance

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Agreement on CSRD and CSDDD Amendment Directive: On 16 December 2025, the European Parliament
voted to approve the proposed ‘CSRD and CSDDD Amendment Directive’…

United States
Corporate/Commercial Law

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Table of Contents

Latest update

Agreement on CSRD and CSDDD Amendment
Directive: On 16 December 2025, the European Parliament
voted to approve the proposed ‘CSRD and CSDDD Amendment
Directive’ which forms part of the Omnibus I Package (the
“Omnibus”). This is the final approval needed before this
Directive comes into effect as the Council had already confirmed on
10 December 2025 that it will approve the European Parliament’s
position. The only steps now required for the Directive to come
into force are procedural steps, including a review by the lawyer
linguists and translation into the 24 official languages and
publication in the EU Official Journal. In this deck, we compare
the final text of the CSRD and CSDDD Amendment Directive against
the existing position under CSRD and CSDDD.

Deferral on additional reporting for wave 1
companies: the ‘Quick Fix’ Delegated Regulation
for wave 1 companies already reporting under CSRD was published in
the EU Official Journal on 10 November 2025. This Delegated
Regulation amends the current ESRS to defer additional reporting
requirements that wave 1 companies under CSRD would otherwise have
been required to meet for reporting on FY2025 and FY2026.

Simplified ESRS: EFRAG released its Draft
Simplified ESRS on 3 December 2025– for more details on the
content please refer to our note here .

Catching up with the Omnibus

The Omnibus proposals, first published by the Commission in
February 2025, aims to simplify the three key pillars of EU
sustainability regulation– CSRD, CSDDD and the EU Taxonomy
framework.¹

These regulations are highly technical, and many organisations
have struggled with implementation. As a result, regulatory
simplification has been a widely supported priority within the
industry. The Omnibus has therefore been broadly welcomed for its
promise to improve usability and simplify regulatory burdens. But
it also creates uncertainty about the future of the EU’s
ambitious sustainability framework to which many companies have
dedicated significant resources.

The CSRD and CSDDDAmendmentDirective has now
beenagreedbyallthreeEU institutions–the Commission, the
Council of the EU and the European Parliament, and we expectit will
be published in the EU Official Journal and to come into force in
early Q12026.

Key proposals in the Omnibus

Next steps

The CSRD and CSDDD Amendment Directive will now be reviewed by
the lawyer-linguists and translated into the 24 official languages,
signed by the Presidents of the European Parliament and the
Council, and published in the EU Official Journal. Publication in
the EU Official Journal is expected in early Q1 2026. The Directive
will enter into force on the date falling 20 days after publication
in the EU Official Journal. EU Member State must then transpose the
changes to CSRD into national law within 12 months after entry into
force (ie by Q1 2027) and transpose changes to CSDDD by 26 July
2028

EFRAG’s final draft of the revised ESRS marks a significant
shift towards simplification, reducing mandatory datapoints and
enhancing interoperability with ISSB standards. EFRAG is expected
to publish the Basis for Conclusions, Explanatory Note and
Cost-Benefit Analysis for the revised ESRS by the end of December
2025, providing further insight into the changes proposed in the
final draft of the revised ESRS. The Commission will use
EFRAG’s advice as the basis for a Delegated Act amending the
existing ESRS, with adoption targeted for mid-2026. For more
detailed insights on the latest published versions of the final
ESRS draft, refer to our note here.

Currentstatusofproposals

Proposed changes to CSRD

1) ‘Stop-the-Clock’ Directive

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Footnote

1. This publication does not cover the amended Regulation
to simplify and strengthen the Carbon Border Adjustment Mechanism
(“CBAM”).

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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