This is the third and final part of the Omnibus series. As a response on the Omnibus Proposal issued by the European commission on 26th of February 2025, we dove into the details to give you some summarize the main proposed changes and share our view on how you can take these to your advantage.
Part one was all about the CSRD and was quickly followed by part two on EU taxonomy. We finish off the series with the changes that have been proposed for the CSDDD. As a regulation that was not in action yet, the sudden change of course was limited for most companies under the CSDDD. Still the responses in the market vary from relieved to outright disappointed. In this blog we will give you’re the update so you can judge for yourself.
The proposed changes at a glance
While the CSDDD had not yet entered into application, the Omnibus proposes significant recalibrations to reduce anticipated administrative burdens. The key proposals include:
- The CSDDD will now apply from 2028 onwards, a one-year delay from the original schedule. The first wave of companies—those with over 5,000 employees and more than 1.5 billion euro in turnover—will be the first to comply.
- Companies will only be required to assess their own operations and those of tier one business partners for actual and potential adverse impacts. The requirement to look into the entire value chain has been removed.
- As with the CSRD, companies will be restricted from requesting sustainability or human rights data from smaller business partners (>1,000 employees). Smaller entities will only be involved based on voluntary standards.
- Instead of assessing the effectiveness of due diligence measures annually, the new rule extends this to once every five years, unless a company has reason to believe that current measures are falling short.
- The controversial 5% turnover-based fine has been removed. Details on future penalty guidelines are still to be developed.
A shifting narrative
The proposed changes significantly shift the original intent of the CSDDD—from broad and ambitious to more focused and manageable. By limiting due diligence obligations to a company’s own operations and direct (tier one) business partners, the Omnibus responds to concerns about administrative burden and legal uncertainty. Many see this as a necessary step to ensure feasibility, while still embedding sustainability and human rights considerations into business practices.
At the same time, critics warn that this narrowing could weaken the directive’s impact. The original value chain-wide scope was seen as a key driver for change beyond a company’s immediate reach. Now, with reduced obligations and extended timelines, the pressure to act may lessen—at least legally. Still, expectations from stakeholders and society remain, making it important for companies to reflect on their role and ambition beyond compliance.
Prepare with purpose
Even though the regulatory landscape around CSDDD is changing, there are still considerations you can keep in mind that might give you that advantage further down the line. Firstly, we advise mapping your direct suppliers. Not only because it will give you insight when preparing for the CSDDD, but also because it will help you in your other sustainability practices. Whether it is to identify potential requests for disclosures coming your way or to have a list of companies you can employ to help you reach sustainable goals, knowing who are your suppliers is key.
Secondly, we advice setting up a scalable due diligence process. While the full value chain assessment is no longer required, building a scalable due diligence system now allows you to go beyond the minimum later—either voluntarily or due to market expectations. Start simple with assessing which impacts might be coming to play in your value chain. Even if you do not need it for the CSDDD (yet), it can give you insights in potential financial risks and focus your efforts to improve your impact.
Harmonizing expectations
With changes to all three major EU sustainability reporting regulations now proposed, companies are navigating a new landscape. The Omnibus may bring relief in terms of timelines and obligations, but it also demands a renewed look at how you plan, prioritize and prepare for sustainable business practices.
Need support to align your strategy with these changes? We’re here to help. Whether you’re a large company within scope or a smaller business facing new expectations, let’s talk about how to move forward—strategically and confidently.
