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The timelines of the Omnibus in the CSRD legislative process

  • Miranda Haak
  • Mar 17
  • 4 min read



Introduction

On February 26, 2025, the European Commission published the first two Omnibus legislative packages. The aim of these proposals is to simplify regulations, reduce the compliance burden for companies and stimulate investment within the EU. The legislative proposals have far-reaching consequences for various legislative processes, including:

· The Corporate Sustainability Reporting Directive (CSRD)

· The Corporate Sustainability Due Diligence Directive (CSDDD)

· The EU Taxonomy

· The Cross Border Adjustment Mechanism (CBAM)


One of the most important components of Omnibus I is the proposed postponement of parts of the CSRD by two years. This would mean that companies from the second wave would only have to report on FY 2027 in 2028, instead of on FY 2025 in 2026.


⚠ Note: This postponement is not guaranteed. It depends on the approval and timely implementation of Omnibus I via a fast-tracking procedure.


Important date: April 1, 2025

The European Parliament has confirmed that the vote on the fast-tracking of Omnibus I COM(2025)80 will take place on April 1.

  • If approved, a vote on the text and possible amendments will follow on April 3.

  • If rejected, Omnibus I COM(2025)80 will have to go through the regular legislative process, which could lead to delays and possibly no postponement of the CSRD.


If the fast-track procedure is approved, this increases the chance that Omnibus I COM(2025)80 will enter into force before December 31, 2025, confirming the postponement of CSRD reporting until 2027.


Background of the Omnibus legislation

The Omnibus legislative packages are designed to simplify and harmonize existing EU legislation. This is necessary to reduce the bureaucratic burden on companies and strengthen the investment climate within the EU.

Within the context of the CSRD, Omnibus I - COM(2025)80 is the most crucial legislative measure. It focuses on the timelines and possible extension of the implementation.


What will change with Omnibus I - COM(2025)80?

The proposed amendments within Omnibus I have two scenarios:


✅ Scenario 1: Fast-tracking is approved (vote on April 1)

✔ Omnibus I COM(2025)80 is fast-tracked and approved.

✔ The changes to the CSRD legislation will enter into force no later than December 31, 2025.

✔ Second wave companies will be granted an additional two-year deferral and will not be required to report on FY 2027 until 2028.


❌ Scenario 2: Fast-tracking is not approved

⚠ Omnibus I doorloopt het reguliere wetgevingsproces, wat kan leiden tot vertraging of zelfs mislukking.

⚠ Als Omnibus I COM(2025)80 niet op tijd wordt aangenomen, blijft de huidige CSRD-tijdslijn gelden.

⚠ Ondernemingen uit de second wave moeten dan alsnog over FY 2025 in 2026 rapporteren zonder uitstel.


Conclusie: De stemming op 1 april is cruciaal voor bedrijven die hopen op uitstel.


Legal implications

The legal consequences of a postponement or no postponement of Omnibus I are considerable.


In case of postponement (CSRD Directive only comes into force in 2027)

  • The EU will have more time to negotiate the substantive changes to the CSR Directive.

  • Companies can adapt contractual obligations and due diligence processes to a longer implementation period.

  • Member states are given extra time to bring national legislation into line with EU directives.

  • Less risk of lawsuits or fines due to non-compliance in the first few years.


If there is no postponement (CSRD will still apply from FY 2025)

⚠ Higher legal risks, such as claims of greenwashing or incomplete sustainability reporting.

⚠ Member states must accelerate the implementation of national legislation, which may lead to inconsistencies within the EU.

⚠ Companies that do not prepare in time run the risk of fines and reputational damage.


In addition, there is legal uncertainty about how member states will approach the implementation of the CSRD. Some countries may decide to implement more quickly the existing guidelines, which could lead to differences in compliance requirements within the EU.


What should companies do NOW?

Given the uncertainty about the approval of Omnibus I, companies from the second wave should be prepared for both scenarios:


1. Monitor the vote on April 1, 2025

  • Follow the negotiations in Brussels and be alert to changes in the law.

  • Analyze the impact of both a postponement and a scenario in which the CSRD is maintained in 2025.


2. Prepare for CSRD, regardless of postponement

  • Start collecting and organizing sustainability data.

  • Make sure internal processes are ready in time for CSRD reporting in 2025 (if postponement does not go ahead).


3. Limit legal and compliance risks

  • Work with legal experts to reduce risks around inconsistencies in national legislation.

  • Ensure a strategy that complies with the CSRD, regardless of whether a deferral is granted.


Conclusion

The CSRD timelines are directly linked to the vote on Omnibus I - COM(2025)80 on April 1, 2025.

  • If the fast-tracking procedure is approved, companies from the second wave will receive an additional two-year deferral until FY 2027.

  • If Omnibus I is not adopted in time, the FY 2025 deadline will remain in force and companies will have to report without deferral.


Companies must act now and prepare for both scenarios.



 
 
 

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