Latest EU Updates on CSRD: Simplified Obligations and How DH Legal Can Guide Your Compliance

The European Parliament's approval of the Omnibus I package on December 16, 2025, marks a pivotal shift in EU sustainability reporting. This definitive agreement scales back the scope of the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD), easing burdens for many companies while maintaining core transparency goals. Businesses now face clearer thresholds and delayed timelines, allowing more focus on genuine performance improvements.

These changes respond to practical challenges, reducing administrative overload without diluting environmental and social accountability. For Dutch firms, national implementation could bring even more flexibility.

Key CSRD Scope Reductions: Who Reports and When?

The revised CSRD targets fewer but larger entities, prioritizing high-impact players.

• Narrowed thresholds: Applies to EU companies with over 1,000 employees and €450 million in revenue. Non-EU firms with €450 million EU turnover, plus their EU subsidiaries or branches exceeding €200 million, remain in scope.

• Public-interest entities (PIEs) relief: PIEs with 500+ employees (originally in "wave 1" for 2024 reporting) may skip reports for fiscal years 2025 and 2026 via a member state opt-out. The Dutch Finance Minister signaled support in a December 3 letter, suggesting Netherlands will likely adopt this—check national laws for confirmation.

• Value chain limits: Companies can only request supply chain data aligned with Voluntary Sustainability Reporting Standards for SMEs (VSME), simplifying data gathering.

These adjustments shrink the reporting population significantly, giving mid-sized firms breathing room.

Other Major CSRD Simplifications

Omnibus I streamlines standards to boost usability.

• No assurance escalation: Drops the plan to raise verification from limited to reasonable assurance, keeping processes manageable.

• Simplified ESRS standards: Sector-specific standards are scrapped; general ESRS rules get pared down.

• Delayed assurance standards: European Commission deadline pushed to July 1, 2027.

For CSDDD (complementary due diligence rules), scope shrinks to EU firms with 5,000+ employees and €1.5 billion revenue (non-EU equivalents too). Climate transition plans are no longer mandatory but must be disclosed if they exist. Due diligence focuses on high-risk activities, with fines capped at 3% of global turnover—phased in from July 26, 2029.

Next Steps in the Legislative Timeline

The European Council will formally approve soon (COREPER already greenlit it), followed by publication in the Official Journal. The directive activates 20 days later, with EU states required to transpose by early 2027. Dutch companies should monitor local updates via the Ministry of Finance.

This timeline lets firms pivot from compliance panic to strategic sustainability.

How DH Legal Helps with CSRD and VSME Reporting

Navigating these updates demands expertise to avoid pitfalls and seize opportunities. At DH Legal, we specialize in turning regulatory complexity into compliant, value-driven reporting for Amsterdam-based businesses and beyond.

• Gap analysis and readiness assessments: We audit your operations against updated CSRD thresholds and VSME standards, identifying exemptions (like the Dutch opt-out) and prioritizing high-impact disclosures.

• Custom reporting frameworks: Build tailored ESRS/VSME templates, integrating double materiality assessments and value chain scoping—fully aligned with simplified rules.

• Assurance and verification support: Guide limited assurance processes, prepare for 2027 standards, and connect you with vetted auditors

• Dutch-specific implementation: Track national transposition, ensuring your 2025-2026 strategies fit local options.

From initial consultations to full report delivery, we handle it all. please contact DH Legal at our Amsterdam offices. We remain committed to guiding clients through these evolving regulatory landscapes.

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