The Impact of the Omnibus I Package: A Major Simplification of CSRD Sustainability Reporting in the EU

The approval of the Omnibus I package by the European Parliament on 16 December 2025, followed by the final endorsement by the European Council on 24 February 2026, marks an important shift in sustainability reporting within the EU. This final agreement narrows the scope of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). It eases the burden on many companies while preserving the core principle of transparency. Businesses now face clearer thresholds and deferred timelines, allowing them to focus more on genuine performance improvements rather than excessive compliance efforts.

These changes respond to practical challenges encountered during implementation. They reduce administrative pressure without weakening environmental and social responsibility. For Dutch companies, the national transposition may even offer additional flexibility.

Key Reductions in the Scope of the CSRD: Who Reports and When?

The revised CSRD focuses on fewer but larger entities, prioritising those with the greatest impact.

• Reduced thresholds: The directive now applies to EU companies with more than 1,000 employees and €450 million in net turnover. Non-EU companies with €450 million in EU turnover, plus their EU subsidiaries or branches exceeding €200 million, remain within scope.

• Relief for public interest entities (PIEs): PIEs with 500+ employees (originally in “wave 1” for reporting in 2024) may opt out of reporting for the financial years 2025 and 2026, subject to member state approval. The Dutch Minister of Finance has indicated support in a letter dated 3 December, suggesting the Netherlands is likely to adopt this option — companies should monitor national legislation for final confirmation.

• Value chain limitations: Companies may only request data from their supply chain that aligns with the Voluntary Sustainability Reporting Standards for SMEs (VSME), significantly simplifying data collection.

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These adjustments substantially reduce the number of companies required to report, giving mid-sized businesses more breathing room.

Other Important Simplifications under the CSRD

The Omnibus I package streamlines the standards to improve usability and practicality.

• No escalation of assurance: Plans to raise the level of assurance from limited to reasonable have been removed, keeping verification processes manageable.

• Simplified ESRS standards: Sector-specific standards have been scrapped; the general ESRS rules have been simplified.

• Deferred assurance standards: The European Commission’s deadline for developing these standards has been postponed to 1 July 2027.

  
  

For the CSDDD (which sets additional due diligence obligations), the scope has been narrowed to EU companies with 5,000+ employees and €1.5 billion in net turnover (with equivalent thresholds for non-EU companies). Climate transition plans are no longer mandatory but must be disclosed if they exist. Due diligence obligations now focus on high-risk activities, with fines capped at 3% of global turnover — phased in from 26 July 2029.

Next Steps in the Legislative Timeline

The European Council is expected to provide formal approval shortly (COREPER has already done so), followed by publication in the Official Journal of the European Union. The directive will enter into force 20 days after publication, with EU member states required to transpose it into national law by early 2027. Dutch companies should closely follow local developments via the Ministry of Finance.

This timeline enables businesses to move away from compliance panic and toward strategic, value-creating sustainability initiatives.

How DH Legal Supports You with CSRD and VSME Reporting

Navigating these regulatory updates requires expert guidance to avoid pitfalls and seize opportunities. At DH Legal, we specialise in translating complex regulations into compliant, value-driven reporting for companies in Amsterdam and across the Netherlands.

Our services include:

• Gap analyses and readiness assessments: We audit your operations against the updated CSRD thresholds and VSME standards, identify available exemptions (such as the Dutch opt-out), and prioritise the most material disclosures.

• Tailored reporting frameworks: We develop custom ESRS/VSME templates that integrate double materiality assessments and value chain scoping — fully aligned with the simplified rules.

• Assurance and verification support: We guide you through limited assurance processes, prepare you for the 2027 standards, and connect you with approved auditors.

• Dutch-specific implementation: We monitor national transposition so your 2025–2026 strategies take full advantage of local options.
  

With this approach, we help companies not only meet the new requirements but also protect and enhance their value while growing with confidence.

Contact DH Legal today for a no-obligation consultation tailored to your situation. Whether you are assessing your new reporting obligations or preparing for national implementation, our experts in Amsterdam are here to support you.