The EU Omnibus Proposal: What Changed — And Why ESG Reporting Still Can't Wait

In February 2025, the European Commission introduced the much-anticipated Omnibus proposal. Marketed as a "simplification package," it aims to reduce reporting burdens on companies while maintaining the core ambition of the EU Green Deal. But what exactly has changed — and what does it mean for your sustainability strategy?

This article outlines the key changes across CSRD, CSDDD, and the EU Taxonomy, and explains why ESG reporting remains a strategic necessity even under the new regime.

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The Three Waves of Impact

The Omnibus proposal impacts three broad categories of companies:

1. PIEs With Over 500 Employees

Companies already obligated to report under the CSRD for the 2024 financial year must continue full reporting according to ESRS. Nothing changes here.

Implication: It’s "business as usual" for this group. Maintain full compliance and prepare for evolving technical updates to ESRS standards.

2. Large Companies With Over 1000 Employees

Originally due to report from 2026 (for FY2025), these companies now have a two-year deferral: their first mandatory report is due in 2028 for FY2027.

Implication: This delay provides breathing room but is a double-edged sword. Companies that use the extra time to build ESG infrastructure will benefit most.

"Double materiality analysis alone can take 3–4 months. ESG data systems often take years to mature."【48†source】

3. Companies Under 1000 Employees

These are now largely exempt from CSRD obligations unless they fall into special reporting scopes. However, they are not off the hook.

Implication: Supply chain pressure, investor expectations, and voluntary standards like the VSME still apply. ESG data will remain a requirement by association.

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What Changed in the CSRD

• Reporting Thresholds Increased: Only companies with over 1000 employees are subject to near-term CSRD obligations.
• Timeline Adjusted: Medium-sized companies get a two-year deferral.
• Audit Requirements Remain: Limited assurance is still expected for sustainability statements.
• ESRS Remains the Framework: The 12 ESRS remain mandatory for in-scope companies, though lighter templates are under discussion.

Key takeaway: The standard hasn’t softened. It has simply become more sequenced.

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What Changed in the CSDDD (Due Diligence Directive)

• Material Scope Narrowed: Applies only to companies with more than 1000 employees and €450 million turnover.
• Frequency of Supplier Audits Reduced: From annual reviews to once every five years.
• Focus on Direct Suppliers: No longer includes indirect tier 2+ suppliers by default.

Implication: Simplifies compliance, but risks overlooking deeper supply chain issues.

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What Changed in the EU Taxonomy

• Reporting Requirements Deferred: Many smaller companies will no longer have to report alignment in the next cycle.
• Green Asset Ratio (GAR): Remains critical for banks and financial institutions.

Implication: Investors will still want to know how green your revenues, CapEx, and OpEx are — even if you're not (yet) mandated to disclose.

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Why ESG Reporting Is Still Urgent

Despite the delays, the Omnibus proposal does not eliminate ESG expectations — it merely redistributes them across time and players.

• Investor Demands Are Rising: Sustainable finance regulations like SFDR still require data from portfolio companies.
• Customers Will Keep Asking: B2B buyers bound by CSRD will push for upstream ESG metrics.
• Banks Need ESG Transparency: EU banking regulation now requires climate-related risk assessments.

In short: ESG data is infrastructure. Building it now means future-proofing your operations.

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Practical Advice for Each Group

Group 1 (Public Interest Entities (PIEs) > 500 employees)

• Keep full ESRS reporting processes in place.
• Consider software-based assurance readiness.

Group 2 (1000+ employees)

• Start with Double Materiality Assessment.
• Pilot ESRS-Lite or VSME templates internally.
• Test reporting infrastructure.

Group 3 (<1000 employees)

• Adopt the VSME Standard as a communication and financing tool.
• Prepare for voluntary disclosures.
• Align with stakeholder requests from banks or customers.

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Conclusion: Delay Is Not Relief. It's an Opportunity.

The EU Omnibus proposal shifts timelines, but not trajectories. Companies that treat this moment as a pause risk falling behind. Those who act now can:

• Gain competitive advantage.
• Build investor confidence.
• Secure green finance.
• Reduce long-term compliance costs.

Waiting is expensive. Whether you’re required to report now or later, building ESG capabilities today is the most pragmatic path forward.

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How Today.Green Helps You Stay Ahead

Whether you're facing immediate CSRD obligations or preparing for future ESG demands, today.green offers the tools and structure to turn complexity into clarity — and deadlines into outcomes.

Built for Every Stage of Maturity
Our modular platform supports all three company groups outlined above — from PIEs managing full ESRS reporting, to mid-sized firms piloting ESG workflows, to suppliers under growing pressure from CSRD clients. No matter where you start, we help you move forward.

Double Materiality, Done Right
We guide you through your double materiality assessment with audit-ready workflows, AI-supported text suggestions, and full alignment with ESRS standards — so your sustainability strategy begins with substance.

VSME Standard Integration
As one of the few platforms offering full VSME support, we make voluntary disclosures efficient, structured, and beneficial — particularly for smaller companies preparing for indirect obligations or seeking green finance.

Automation Without Black Boxes
Our software streamlines ESG data collection, emission calculations, and reporting — but always with transparency. Every number can be traced, every document versioned, and every report customized.

From Pilot to Platform
Use today.green to test lightweight reporting (e.g., GHGP or VSME), train internal teams, and gradually scale into a robust ESG infrastructure. We’re built for long-term integration — not quick compliance hacks.

Hands-On Support, Always
You’re not alone. Every customer receives dedicated access to a today.green expert — via email, phone, or joint work sessions. We help you connect the platform to your ESG reality.

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