ARTICLE
15 December 2025

Provisional Agreement On Omnibus Amendments To CSRD And CSDDD

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The European Parliament and Council have reached a provisional agreement on the Omnibus amendments to the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).
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The European Parliament and Council have reached a provisional agreement on the Omnibus amendments to the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).

The agreed text is not yet available, but press releases from the European Parliament and Council confirm the following:

CSRD

  • Scope thresholds: For EU companies, there is an employee threshold of 1,000 employees and a net turnover threshold of EUR 450 million. For non-EU companies, the net turnover threshold is increased to EUR 450 million.
  • Listed SMEs: Removed from scope.
  • Financial holding undertakings: Exempt from scope.
  • Wave one reporters: A transition exemption will apply for "wave one" companies falling out of scope for 2025 and 2026.

CSDDD

  • Scope thresholds: For EU companies, there is an employee threshold of 5,000 employees and a net turnover threshold of EUR 1.5 billion. For non-EU companies, the EU net turnover threshold is EUR 1.5 billion.
  • Due diligence: Companies to adopt a risk-based approach, focusing on areas of the chain of activities where adverse impacts are most likely to occur.
  • Climate transition plan: The obligation to adopt and put into effect a transition plan for climate change mitigation has been removed.
  • Civil liability: The EU harmonised liability regime is removed.
  • Timeframe: The CSDDD transposition deadline is extended to 26 July 2028, with first application from July 2029.

The provisional agreement introduces a review clause concerning a possible extension of the scope for both CSRD and CSDDD.

Next steps

Formal approval of the provisional agreement is required from both the European Parliament and the Council.  

ESRS simplification

On 3 December 2025, EFRAG submitted its technical advice to the European Commission on revised ESRS.  The Commission is expected to adopt revised ESRS via a delegated act within six months of the Omnibus amendments to CSRD entering into force.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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