{"id":10881,"date":"2025-03-14T12:28:54","date_gmt":"2025-03-14T12:28:54","guid":{"rendered":"https:\/\/vpwhite.com\/?p=10881"},"modified":"2025-09-18T15:48:30","modified_gmt":"2025-09-18T15:48:30","slug":"projet-de-directive-omnibus","status":"publish","type":"post","link":"https:\/\/vpwhite.com\/en\/projet-de-directive-omnibus\/","title":{"rendered":"Omnibus Directive Project\u00a0"},"content":{"rendered":"
\r\n
\r\n \r\n <\/i>\r\n <\/a>\r\n <\/span>\r\n<\/div><\/div>\t\t
\n\t\t\t\t
\n\t\t\t\t\t
\n\t\t
\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tCSRD\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tCSDD\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tCS3D\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tGreen Taxonomy\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tOmnibus\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tESG reporting\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tSustainability\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tCompliance\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
\n\t\t\t\t\t
\n\t\t\t\t
\n\t\t\t\t\t

Simplification of the CSRD, the CS3D and the Taxonomy: what will this mean for businesses?<\/h1>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\t

The European Commission has announced its intention to simplify and harmonise the reporting framework for European companies. With this in mind, on 26 February it officially presented the \"Omnibus Package<\/strong>\", a set of proposals aimed at simplifying and adjusting the texts of the CSRD, the Green Taxonomy and the Duty of Vigilance Directive, the CS3D<\/strong>.<\/p>

An \"Omnibus\" law is a piece of European legislation that brings together several amendments to existing directives or regulations in a single act. Its purpose is generally to adjust several pieces of legislation at the same time, thus avoiding the need to adopt several separate texts.<\/p>

What are the main changes announced? What happens next in the legislative process? How can companies adapt and anticipate in this regulatory context?<\/p>

Deciphering the Omnibus package and the actions to be taken.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t

\n\t\t\t\t
\n\t\t\t\t\t

What are the main changes announced?<\/h1>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t

Simplification of CSRD and ESRS<\/h2>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t

Lowering of applicability thresholds<\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\t

The CSRD (Corporate Sustainability Reporting Directive) currently applies to companies with more than 250 employees and sales in excess of \u20ac40 million. It requires detailed reporting based on the European Sustainability Reporting Standards (ESRS), covering environmental, social and governance (ESG) criteria, to strengthen transparency and corporate responsibility in terms of sustainability.

One of the most emblematic measures of the Omnibus project is the lowering of the thresholds for the directive's applicability, reducing the number of companies concerned.

If the proposal is adopted, the CSRD will only apply to companies with more than 1,000 employees<\/strong> and a turnover of \u20ac50 million<\/strong>, thereby exempting more than 80% of the companies initially concerned<\/strong>.

As a result, the number of companies included in the scope of the CSRD would fall from more than 50,000 to less than 10,000 companies<\/strong>.<\/p>

The thresholds for non-European companies have also been raised, from \u20ac150 million to \u20ac450 million turnover<\/strong>.

The revision of these thresholds would be justified by a desire to align the CSRD with the CS3D.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

\n\t\t\t\t
\n\t\t\t\t\t

Voluntary reporting by SMEs<\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tSMEs that will no longer be subject to the reporting obligations arising from the CSRD will be able to use the \"VSME\" (Voluntary reporting standard for Small and Medium Enterprises) proposed by EFRAG, which will be adopted in the form of a delegated act. \t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
\n\t\t\t\t
\n\t\t\t\t\t

Review of ESRS<\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\t

It has been proposed that the ESRS be revised, in particular by simplifying the structure and presentation of the reporting standards.

The revision also provides for a reduction in the number of mandatory data points,<\/strong> prioritisation of quantitative data over narrative elements, and improved interoperability<\/strong> with international reporting standards.

This simplification proposal will be presented in the form of a delegated act no later than 6 months after the entry into force of the Omnibus Directive.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

\n\t\t
\n\t\t\t\t
\n\t\t\t\t\t

Clarifications on dual materiality<\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tWhile the principle of double materiality has been maintained, its application should be more clearly defined to avoid companies declaring irrelevant information.\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
\n\t\t\t\t
\n\t\t\t\t\t

Audits <\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tThe gradual transition from limited insurance to reasonable insurance has been abolished. \t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
\n\t\t\t\t
\n\t\t\t\t\t

\"Stop the clock\": publication reports<\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tA 2-year postponement is proposed for the disclosure of the first company reports and audits, which were initially due to be published in 2026 and 2027. \t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
\n\t\t\t\t
\n\t\t\t\t\t

Cancellation of sector ESRSs <\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\tThe creation of sector-based ESRSs has been cancelled to avoid increasing the volume of data to be published. \t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
\n\t\t\t\t
\n\t\t\t\t\t

2. Reduction in the scope of the CS3D<\/h2>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\t

The CSDD or CS3D (Corporate Sustainability Due Diligence Directive) requires large companies to prevent and mitigate the negative impacts of their activities on human rights and the environment<\/strong>. To achieve this, companies must identify and assess the impacts of their activities across their entire value chain<\/strong> (upstream and downstream). The Directive applies to companies with a turnover in excess of \u20ac450 million and more than 1,000 employees.<\/p>

With the Omnibus project, the scope of the CS3D should be reduced:<\/strong>the supplier risk assessment, initially intended to cover indirect suppliers, would now be applied only to direct suppliers. It would only be extended to indirect suppliers in the event of plausible information suggesting negative impacts - real or potential - at their level.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t

\n\t\t\t\t\t

Other changes made to the CS3D by the Omnibus Package: <\/h3>\t\t\t\t<\/div>\n\t\t\t\t
\n\t\t\t\t\t\t\t\t\t