Update (December 16, 2025).
Omnibus I was finalized on Dec. 16, following the vote on Nov. 13, 2025, with the EU opting for simplification of CSRD and CSDD obligations, while the strategic relevance of transparent sustainability data remains undiminished.
With the final adoption of Omnibus I on December 16, 2025, the new European choices around sustainability reporting are a reality. The simplification of CSRD and CSDD obligations follows months of political decision-making and marks a clear change of direction in European sustainability policy.
For companies, this brings significant changes: some obligations are significantly reduced and an EU portal will be established to further streamline reporting. At the same time, a new layer of uncertainty has been created by criticism from the European Ombudsman of the way the Commission has prepared the proposals.
In this article you will read what has been decided, what impact this has on CSRD, ESG reporting and due diligence, and how Milgro views it.
What did the EU vote and what does Omnibus I mean after Dec. 16?
According to the EP press release , the key elements are:
- 382 in favor, 249 against, 13 abstentions: the EP agreed to the simplification proposal.
- CSRD only for the largest companies: companies with ≥ 1,750 employees and > €450 million turnover are still covered by the reporting obligation.
- CSDD limited to very large companies: ≥ 5,000 employees and > €1.5 billion turnover.
- Less reporting content: sector-specific reporting standards will become voluntary; qualitative detail requirements will be reduced.
- New EU portal becomes available with free templates, formats and guidelines.
This means that a very large proportion of companies that would previously have been covered by CSRD are now left out of the obligation.
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New dimension: criticism from the European Ombudsman
The European Ombudsman published its findings on the European Commission's preparation of the Omnibus proposal in November. It found that the Commission did not act with sufficient care and transparency.
Main signals:
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inter-service consultation times were extremely short (sometimes less than 24 hours, including a weekend);
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documentation on the required climate consistency assessment is missing, while this is mandatory for proposals with environmental impacts.
This puts pressure on the legitimacy of the process and may lead to adjustments or additional safeguards during the trilogues.
With the December 16 vote, the outline of Omnibus I was adopted. The focus on simplification and scope limitation has thus become final policy, although there remains room for interpretation in national implementation.
What does Omnibus I mean for companies?
Fewer obligations, but not fewer expectations
Although many medium-sized companies fall outside the formal CSRD scope, the demand for reliable sustainability data from customers, investors andsupply chain partners remains as high as ever. Thus, transparency remains relevant even without a legal obligation.
Voluntary reporting becomes more strategic
Those who report voluntarily now :
- creates a head start on future obligations,
- meets market expectations,
- strengthens their own supply chain position,
- demonstrates maturity to investors and funders.
Preparing remains essential
Companies that stop data collection increase risks:
- lack of understanding of circularity, waste streams, CO₂, risks,
- higher costs later with new regulations,
- lag in chain cooperation.
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Why companies should not wait now but act ahead
Gijs Derks, director of Milgro says: "The new EP position is a clear choice for simplification, but at the same time it brings a fundamental shift. By raising the thresholds for CSRD and CSDD reporting so much, a large part of the European economy is at risk of being out of the picture. In fact, transparency, data quality and chain traceability are essential to make sustainability credible.
The fact that the European Ombudsman now indicates that the preparation of the proposal is procedurally flawed underscores that the rules are far from final. Companies that scale back their efforts now are thereby taking a real strategic risk.
My advice is clear: use this moment to get ahead, not stall. Organizations that properly organize their data management, waste and material streams and supply chain accountability now will be stronger in the future regardless of what the final legislation will look like.
At Milgro, we believe that transparency is not an obligation, but a competitive advantage. We help companies use data to improve performance, reduce costs and operate future-proof.
The final adoption of Omnibus I on Dec. 16 confirms that the EU is opting for fewer obligations, but not less transparency. Legal pressure is decreasing for many companies, while market pressure from customers, financiers and supply chain partners remains structural. This definitely shifts sustainability from compliance to strategic choice."
How to move forward with CSRD and Omnibus?
With the final adoption of Omnibus I on December 16, the simplified obligations around CSRD and CSDD are now a reality. For many companies, this means that the legal pressure is easing, but the demand for reliable sustainability data from customers, investors and supply chain partners remains as strong as ever. Companies that continue to invest in data management and transparency now will thereby strengthen their position and future-proofing, regardless of how the market or further regulations develop.
Milgro helps with:
- data management for waste, CO₂ and circularity
- preparing for the new EU portal and templates
- ESG reporting and data enrichment
- supply chain analyses and due diligence support
Getting started with CSRD within the Omnibus package
Want to know what the CSRD requires of your organization and how you, as a waste manager, can respond? Visit our dedicated CSRD page. Here you'll find all the information clearly presented, a handy starter pack to get you started, and access to our informative webinar.
Staying informed
Stay up to date with all the new developments around the CSRD and the Omnibus Package? Follow us onLinkedIn, listen to the podcast "Feedstock to Think" or subscribe to the newsletter. Are you curious about what Milgro can do for your organization ? Then book a no-obligation introductory meeting.
