How Companies Can Respond to the Omnibus Legislation

Strategic Scenarios in a Changing Sustainability Landscape

The announcement of the Omnibus legislation by the European Commission on February 26, 2025, marks a significant moment of recalibration for the sustainability reporting landscape. The proposed changes affect several major frameworks, including the CSRD (Corporate Sustainability Reporting Directive), CSDDD, and the EU Taxonomy.

For companies, this may mean reconsidering previously defined reporting strategies and implementation plans. At the same time, these developments create space for more efficient and targeted decision-making that aligns with an organization’s strategy, ambition, and risk appetite.

What Does the Omnibus Ask of Companies?

The Omnibus proposes, among other things:

• Adjustments to timelines for certain large companies

• Relaxation of reporting obligations

• A shift in data point priorities toward quantitative indicators

• Simplification of sustainability reporting requirements

This calls for organizations to reassess their direction—not just legally and operationally, but also strategically. How does the Omnibus relate to a company’s own sustainability ambitions, such as achieving Net Zero by 2050, further integrating social issues into operations to attract and retain employees, and—crucially—meeting the information needs of financial institutions, enabling them to reallocate capital toward the company?

Three Strategic Scenarios to Consider

Based on the potential impact of the Omnibus, companies may choose between three strategic scenarios:

🟢 Scenario 1 – Phased Progress

What does this mean?

The organization continues to build on current legislation but adjusts its execution depending on evolving legal and political developments. Activities are categorized as ‘no-regret’ (continue) or ‘regret’ (pause).

Key Features:

• Flexible progress without standstill

• Regular reassessment of activities

• Risk control while maintaining momentum

Best suited for:

Organizations that wish to keep moving forward while managing uncertainty cautiously.

🟡 Scenario 2 – Strategic Wait-and-See

What does this mean?

Implementation efforts are largely paused until there is clarity on the final legislation. Only essential work for other requirements (e.g. SFDR or supply chain due diligence) continues.

Key Features:

• Cost and capacity control

• Deliberate choice to hold off on potentially changing rules

• Clear communication required toward stakeholders

Best suited for:

Organizations that prefer caution in light of uncertainty, are less dependent on external capital, and/or need to prioritize other matters first.

🔵 Scenario 3 – Full Speed Ahead

What does this mean?

The organization adheres to the original requirements of CSRD and the Taxonomy, regardless of the Omnibus. Reporting structures, data infrastructure, and processes are fully implemented according to existing frameworks.

Key Features:

• Maximum preparation and compliance

• Higher short-term workload

• Less dependency on political developments

  
  

Best suited for:

Organizations with strong sustainability ambitions or external expectations (e.g. investors or public clients), or those that have embedded sustainability into their core strategy.

🔍 Essential Elements Across All Approaches

Regardless of the chosen scenario, organizations should:

• Assess which strategic commitments they have already made (e.g. covenants, ISO standards)

• Identify data points that may also be relevant under other regulations for attracting investment (e.g. SFDR, DORA, CSDDD)

• Map supply chain obligations and contractual agreements

• Explore synergies with other initiatives (e.g. IT transitions or ESG integration)

📌 In Conclusion

The Omnibus proposal offers an opportunity to recalibrate sustainability reporting efforts. The best strategy will depend on an organization’s strategic goals, risk tolerance, and long-term direction.

What is paused today may become urgent tomorrow. And what continues today, may be a gamechanger tomorrow.

Make sure to choose a well-founded path—one that considers both the external landscape and your internal long-term vision.