On February 26, 2025, the European Commission released the much-discussed Omnibus proposal—just as the first wave of companies finalized their annual reports and the next wave is deep into materiality assessments, gap analyses, and data collection for the upcoming year. What does this proposal mean for companies operating in Sweden and the EU if it passes? And how should businesses approach their sustainability work and reporting while the legislation remains unclear
Senior Consultant and Team Lead Rebecka Jakobsson, alongside Senior Consultant and Partner Malin Forsgren from 2050, explored these questions in a webinar on March 7, 2025. Below, we summarize the key takeaways from the session. A link to the full recording is available at the end of this article.
The Omnibus Proposal: Key Changes
The Omnibus proposal builds partly on the Draghi Report, published in September 2024, which raised concerns that European companies are losing competitiveness due to excessive bureaucratic demands. The proposal includes changes related to CSRD, CSDDD, the Taxonomy Regulation, and CBAM. Specifically, for CSRD, the proposal has two main objectives: delaying implementation and simplifying the legislation while significantly reducing the number of companies subject to reporting requirements.
Major Changes Compared to Current Legislation
CSRD
- Delayed implementation: To allow the new legislation to be decided by the EU and member states, the Commission proposes a fast-track pause on reporting for all but large publicly traded companies (over 500 employees) that are already reporting.
- Revised thresholds: Companies with fewer than 1,000 employees will no longer be required to report, while larger companies must continue reporting under ESRS standards (no distinction between publicly listed and private companies).
- Simplified standards: The sector-specific reporting standards previously announced will not be introduced.
- Reduced reporting requirements: ESRS standards will be streamlined, removing a substantial number of datapoints.
- Limited value chain reporting: Requirements to disclose information related to the entire value chain will be restricted.
- Audit requirements remain unchanged: Unlike previously planned, non-financial data will not be subject to the same level of auditing as financial data. The current limited assurance requirements will still apply.
- Governance and strategic alignment requirements remain: Board accountability, tagging of data for comparability and input to investment decisions, as well as integration of sustainability with business strategy are not addressed in the Omnibus proposal and are expected to remain in place for affected companies.
- Double materiality analysis: Despite speculation before the proposal’s release, the requirement for double materiality assessment remains for companies subject to CSRD.
Taxonomy:
- Only companies with more than 1,000 employees and revenue exceeding €450 million will be subject to the EU Taxonomy Regulation.
- The number of required data points will be reduced, and a materiality parameter will be introduced.
CSDDD:
- The legislative requirement is proposed to be delayed.
- Due diligence obligations regarding value chains will be eased (limited to direct suppliers with at least 1,000 employees).
- Reporting requirements will be reduced.
CBAM:
- A reporting and fee exemption will be introduced for imports below 50 tons per year.
- This change will exempt approximately 90% of companies currently reporting under CBAM while still covering 99% of the carbon emissions within the scope of the regulation.
What This Means for Businesses
The most immediate consequence of the proposal is uncertainty. It is unclear exactly how and when the legislative changes will be implemented, making it difficult for companies to plan ahead. The impact will vary across different types of businesses. If the proposal is passed, smaller companies will face less regulatory pressure to report. However, stakeholder expectations may still necessitate continued sustainability reporting. Meanwhile, large companies with more than 1,000 employees will still be required to report but under new, simplified standards that have yet to be finalized.
Key implications, particularly regarding CSRD amendments:
- Reduced administrative burden
- Potential to allocate more resources toward sustainability initiatives and innovation
- Uncertainty about how and when the proposal will take effect
- Reduced transparency and limited access to supplier and value chain data, making it harder to manage impacts, risks, and opportunities
- Weaker data quality may hinder effective and value-driving sustainability measures
- Less comparability between companies, as businesses with fewer than 1,000 employees will no longer have standardized reporting requirements
- Companies may be less prepared for future regulatory and stakeholder demands
Recommended Actions for Businesses
Sustainability challenges remain as urgent as ever, particularly concerning climate change and biodiversity loss and the EU’s climate and environmental goals remain unchanged. Maintaining or accelerating sustainability efforts in response to business impact, risks, and opportunities is crucial, as sustainability remains a key strategic value driver. Staying ahead can foster resilience, competitive advantages, and long-term value creation.
Here are some actionable next steps:
- Identify sustainability drivers beyond regulatory requirements – Understand what customers, investors, and other stakeholders expect regarding sustainability performance and reporting.
- Use double materiality as a foundation for a long-term sustainability strategy – Conduct scenario analyses to gain a holistic view of sustainability risks and opportunities relevant to your business.
- Monitor regulatory developments closely – Keep track of EU regulatory changes and prepare for different scenarios. Be ready to adapt your reporting plans if necessary while ensuring your sustainability strategies remain robust.
- Stay informed about related sustainability regulations and initiatives – Ensure your business is aware of relevant laws and policies that may directly or indirectly impact your operations.
For more insights, watch the full recording of our webinar (in Swedish) here!
This article is part of 2050 Highlights, a series where we explore pressing sustainability and business topics. Want to learn more about how your company can navigate the evolving regulatory landscape? Contact us at 2050!
Read more about the Omnibus proposal here: Commission proposes to cut red tape and simplify business environment – European Commission
Check out all our upcoming trainings and webinars here!
