EU sustainability reporting Omnibus reaches destination as Content Directive agreed

What you need to know

• The EU legislators have reached a provisional agreement on the First Omnibus Package Content Directive, which will make substantive changes to the Corporate Sustainability Due Diligence Directive ((EU) 2024/1760) (CS3D) and the Corporate Sustainability Reporting Directive 2022/2464 (CSRD).
• Key changes to the CSRD include increases to qualification threshold criteria and removal of the requirement for the Commission to adopt reasonable assurance standards.
• Key changes to the CS3D include increases to threshold criteria, removal of the requirements to develop and publish climate transition plans and removal of the provisions regarding a harmonized EU civil liability regime.
• The EU Council and EU Parliament must now endorse and formally adopt the provisional agreement, and the final text of the Content Directive will then be published in the EU Official Journal.
• Following EFRAG's technical advice to the EU Commission on draft revised European Sustainability Reporting Standards (ESRS), the Commission will prepare legislation to amend the ESRS adopted in 2023.

What you need to do

• EU companies and non-EU companies with EU-subsidiaries or branches that were previously in-scope of the CSRD or CS3D will need to review their previous analysis to understand if they remain in-scope and what their sustainability reporting and due diligence obligations will be going forward.

The European Commission's First Omnibus Package included a proposed directive known as the Content Directive that will make substantive changes to the Corporate Sustainability Due Diligence Directive ((EU) 2024/1760) (CS3D) and the Corporate Sustainability Reporting Directive ((EU) 2022/2464) (CSRD) (see EU Commission publishes first Omnibus Package to simplify sustainability regulations).

In November 2025, the EU Parliament adopted its negotiating position on the Content Directive. The trilogue negotiations between the EU Parliament, the EU Council and the Commission resulted in a provisional agreement on 9 December 2025.

The provisional agreement needs to be officially adopted by both the European Parliament and the Council.  Member States' ambassadors will vote on the provisional agreement at the COREPER meeting on 10 December 2025, paving the way for official adoption by the Council  The EU Parliament's Legal Affairs Committee will vote on the provisional agreement on 11 December 2025 and a vote has been tabled for the EU Parliament plenary session to be held on 16 December 2025.

The final text of the Content Directive will then be published in the EU Official Journal.

The table below sets out what has been agreed on the key issues as highlighted by the EU Council and EU Parliament press releases. The final text of the Directive is expected to be available in the coming days. For an understanding of the position in the original Directives and the legislators' negotiating positions, see EU Commission publishes first Omnibus Package to simplify sustainability regulations.

What is happening regarding the ESRS?

In July 2025, the European Financial Reporting Advisory Group (EFRAG) conducted a consultation on a simplified set of ESRS (see EU Parliament agrees position on sustainability reporting Omnibus Content Directive). 

On 3 December 2025, EFRAG provided its technical advice to the European Commission on the draft revised ESRS. 

The revised ESRS reduce the mandatory datapoints in the first version of the ESRS that were published in Commission Delegated Regulation (EU) 2023/2772 by 61%. Key changes include:

• Simplifying the materiality assessment to better align with audit requirements and providing clearer guidance, although the concept of double materiality is retained.
• Enhanced interoperability with the International Sustainability Standards Board's (ISSB's) standards including though emphasising fair presentation of information to ensure disclosures are relevant, revised GHG boundary and reliefs concerning anticipated financial effects (e.g. in relation to data quality, sensitivity of information and difficulties relating to preparation and audit caused by lack of standardised methodologies).
• Emphasising the need for conciseness in sustainability statements, for example by providing an executive summary and using appendices for more detailed information. The rules on referencing other information (such as others parts of the management report, the financial statements or the corporate governance statement) have also been clarified.
• Eliminating the preference for direct data rather than estimates in relation to value chain information, reducing the pressure for data collection.
• Providing new reliefs, proportionality mechanisms (such as only requiring “reasonable and supportable information that is available without undue cost or effort”) and phasing-in for harder disclosures. One relief of note is the ability to delay a materiality assessment and reporting by a year in relation to acquisitions and disposals.
• Deletion of all voluntary disclosures.

The next step is for the Commission to prepare a Delegated Act revising the first set of ESRS based on EFRAG’s technical advice. This is expected within six months after the entry into force of the Content Directive.

EFRAG has also published a Knowledge Hub to help companies with reporting obligations under the CSRD to navigate the revised ESRS and related documents.

The Omnibus process has resulted in significant changes to the Commission's February 2025 proposals. Commentators suggest that over 90% of companies originally in-scope of the CSRD and the CS3D will be excluded from the scope of the revised Directives.

For legal and sustainability reporting teams, the simplification exercise is likely to result (initially at least) in more work as they get up to speed with the reporting and due diligence requirements. 

If you require support on whether you remain in-scope of CSRD or CS3D and/or to understand your revised obligations, please get in touch with any of the contacts below.