Change in scope and shift in priorities: what is in there for my board?
On October 13, 2025, the Committee on Legal Affairs of the European Parliament approved the so-called Omnibus Deal: a reduced scope for sustainability reporting and due diligence that has been agreed upon the week before. The Deal is a final agreement on the Omnibus proposal that the EU Commission made in February 2025 to reduce regulatory burden.
According to the Deal, CSRD regulation will now be applicable to companies with at least 1,000 employees and €450 million in turnover. The original Omnibus proposal was based upon the same number of employees in CSRD reporting: at least 1,000, and €50 million in turnover, i.e. 9 times less. Originally, Omnibus proposal itself reduced the number of companies required to report, by 80%.
Also the scope of CSDDD was reduced significantly in the Omnibus Deal: from 1,000 employees to 5,000, and from 450 million turnover to 1.5 billion net turnover.
This compromise took over 6 months to reach; its economic, social and climate implications are still to assess. While the news feels as a relief from a reporting burden, it also indicates a certain tension between strategic priorities and practical solutions at the level of the united Europe.
Here are certain questions for boards to reflect upon.
Is there a shift in EU priorities: is sustainability exiting the radars of block’s political leaders?
Should we expect a higher level of uncertainty coming from the EU level? So far, the main effort of EU policy makers was focused on creating transparency through regulation. Regulation comes at a cost, and the latter became too high for the European business, pushing the pendulum in the opposite direction, for less regulation and even de-regulation. The Omnibus Deal illustrates that the choice of fields for de-regulation depends on political consensus, and thus could be arbitrary.
Will the Deal augment market asymmetry, favouring short-term gains over long-term focus? Sustainability reporting has a room for improvement, however it remains a tool for measuring company’s performance and allows clear communication of this performance to the outer world.
The Omnibus Deal raises a question on how to proceed with complex issues that require coordinated efforts of the majority. Regulation seems too bulky, but self-regulation is not enough, if it remains a choice of the most advanced long-term focused champions in the short-term focused environment.
GUBERNA members have emphasised the need to boost competitiveness and innovation in order to empower European companies at the global scale. What specific actions would your board go for to advance sustainable value creation?