On Feb. 26, the European Commission (EC) published the Omnibus legislative proposal. This proposal contains a package of amendments to existing legislation around sustainability reporting, including the CSRD (Corporate Sustainability Reporting Directive), the CSDDD (Corporate Sustainability Due Diligence Directive) and the EU Taxonomy.
The purpose of these changes is to ease the reporting burden on companies and make the rules simpler. Since many of our clients are subject to CSRD reporting requirements, we dove in.
What did we find out? The implications of the Omnibus Package for CSRD are mixed everywhere. In this blog we list what has changed and what that means for your organization.
Omnibus and the CSRD report
The introduction of the Omnibus package may affect your CSRD reporting. We list the most important proposed changes:
- Fewer companies are covered by the CSRD reporting requirement. The criterion for the number of employees has been changed from 250 to 1,000. As a result, it is estimated that some 80% of companies that were previously subject to reporting requirements will no longer have to comply with the CSRD.
- Postponement of 1 to 2 years for most companies. The reporting requirement is deferred for most organizations. An important exception are listed companies that are already covered by the Non Reporting Directive (NFRD). They will still have to report this year for 2024 under the CSRD.
- Voluntary reporting for smaller listed companies (SMEs). There is no mandatory CSRD reporting for this group. They may report voluntarily.
- Fewer mandatory data points within selected themes. Companies are required to report on fewer data points within the themes (ESRS chapters). Exactly which data points will be dropped is not known at this time.
Omnibus package and the impact on your business
Organizations that were preparing for CSRD reporting no longer appear to be required to do so in many cases. This is especially true for companies that were required to report only on the basis of the old employee criterion of 250 employees. With the proposed increase of this criterion to 1,000 employees, they may now fall outside the CSRD. Listed SMEs are also not subject to mandatory reporting for the time being. As a result, planned investments in data collection, internal processes and reporting will be paused or reversed in some cases.
For companies that do remain CSRD mandatory, reporting is expected to become simpler. For example, the number of mandatory data points within selected themes (ESRS chapters) will be reduced. Exactly which data points will be dropped is not known at this time.
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Omnibus package: current developments
The Omnibus Package is currently in the implementation phase. It is expected that companies will have to comply with the new guidelines as of the reporting year 2026. In the run-up to this, national governments will translate the European changes into concrete laws and regulations. For the Netherlands , these directives are expected to be published in mid-2025, allowing companies to prepare in time. A similar deadline applies in Belgium .
Stay up to date with the most current information around the Omnibus Package? Follow us on LinkedIn and don't miss a thing.
Our perspective: benefits over administrative burden
At Milgro, we understand that the changes in regulations due to the Omnibus Package present challenges. This package is designed to simplify the administrative processes around, for example, the CSRD. A major consequence is that fewer companies are subject to the reporting requirement. A missed opportunity. Those who are already committed to transparency and chain responsibility now will soon be better prepared-not only for reporting, but also for improving their own performance on waste and circularity.
In our experience, thorough preparation for CSRD yields much more than compliance. A well-executed materiality analysis provides deep insights into opportunities and improvement possibilities within your organization. These insights offer opportunities for cost savings, more sustainable operations, better risk management and sharpening of strategic choices - for example regarding investments, chain collaborations or your position in the market. In our opinion, you get more out of the mater
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Download de gratis CSRD startkit
Aan de slag met CSRD binnen het Omnibuspakket
Want to know what the CSRD requires from your organization — and how you, as a waste manager, can respond effectively?
Visit our dedicated CSRD page. Here you’ll find:
• all relevant information clearly organized
• a practical starter kit to help you get started right away
• access to our informative webinar
Keeping up to date
Want to stay up to date on all new developments concerning the CSRD and the Omnibus Package? Follow us onLinkedIn, listen to the podcast 'Raw material for thought' or subscribe to the newsletter. Are you curious about what Milgro can do for your organization ? Then book a no-obligation introductory meeting.
