With the omnibus package (COM(2025) 80, 81, 87), the EU Commission aims to simplify reporting obligations (CSRD/ESRS), due diligence (CSDDD), and the carbon border adjustment mechanism (CBAM). For businesses, this involves less bureaucracy, clearer application areas, and reliable deadlines. Positive developments include higher thresholds for CSRD, a value-chain cap through the VSME standard, taxonomy options, and a 50-tonne exemption for CBAM. Timely adoption with practical transitional rules is now essential – so that investments in transformation and competitiveness are not stifled by uncertainty.
In Brief
- CSRD: Plans for relief (e.g., threshold of 1,000 employees, removal of sectoral ESRS), Value Chain Cap via SMEs.
- CSDDD: Partial harmonisation, fewer bureaucratic obligations, but ongoing requirements for plausible risks in deeper chains.
- Taxonomy: Voluntary reporting for parts of companies; simplified reporting templates announced.
- CBAM: 50-tonne exemption, standard values, more anti-circumvention rules – registration obligation remains a critical issue.
- Urgent: swift decision-making, clear transition rules and coherence between CSRD, CSDDD, financial supervision, and customs processes.
Background
Environmental regulations often lead to high costs, additional reporting and documentation obligations, as well as lengthy and complex permitting processes. Many requirements stem from EU legislation and are implemented differently among member states, straining the internal market. The EU Commission announced an "environmental omnibus" for Q4/2025 and aims to simplify compliance with extended producer responsibility. Additionally, potential for standardisation, relief, and clarity exist in various other regulations – such as EUDR, PPWR, IED, RoHS, WEEE, Single-Use Plastics Directive, and EIA/IE procedures. The DIHK proposes specific adjustments to maintain environmental goals while avoiding excessive bureaucracy.
What matters for businesses
- Scope check: Will your company only fall under CSRD from 1,000 employees onward? Review deadlines (likely from fiscal years 2027/2028) and prepare materiality analyses, processes, and systems in time.
- Focus on supply chains: Streamline inquiries along the chain and – once available – use the VSME basic module as a standard for data requirements of non-reporting SMEs (once-only principle, consider interfaces with ERP/reporting tools).
- Optional taxonomy reporting: Where permissible, reduce effort; at the same time, structure internal data systems for later expansion without media disruption.
- Prepare for CBAM: Consolidate CBAM goods import volumes, check the 50-tonne yearly threshold, explore availability of emission data, and plan standard values as a fallback; harmonise processes with customs service providers.
- Audit and IT planning: Factor in adjustments from ESRS revisions (data models, controls, audit readiness), but stagger investments based on the enactment date and national implementation.
DIHK's demands
- Legal certainty: Retroactively suspend sanctions for the "first wave" of CSRD and set clear transitional rules; apply amended ESRS with sufficient lead time.
- Focus on CSRD: Design thresholds consistently and practically; effectively limit value-chain requirements (Tier‑1 focus), define the VSME base as a binding cap and enforce it coherently across Europe.
- Ensure coherence: Align financial supervision (guidelines/reporting by institutions) with the VSME base; recognise international standards (including ISSB) as interoperable; assess ESEF obligations for necessity.
- Targeted CSDDD: Define core rights/prohibitions clearly and measurably; establish a "white list" for countries with high protection levels; make liability and sanctioning systems proportionate and consistent across Europe.
- Practical CBAM: Allow choice between registration/certificates trading and simplified customs settlement based on standard values; quickly decide on the 50-tonne exemption and regularly evaluate standard value methodologies.
FAQ
Frequently Asked Questions
- From when are the exemptions effective?
As long as the Council and Parliament have not passed and published the proposals, the current obligations remain in effect. Companies should plan with scenarios and observe transitional rules. - What is the VSME standard and what is its use?
The voluntary SME standard (VSME) is intended to provide a uniform, lean dataset for sustainability inquiries along the chain – as a 'cap' for supplier inquiries and to relieve SMEs not subject to reporting obligations. - Am I affected by the 50-tonne limit for the CBAM?
Add up the annual quantities of CBAM-liable goods (per importer). Importers are exempt below 50 tonnes. Processes should be clarified early on with customs service providers in borderline cases. - What if suppliers do not provide emissions data?
The use of standard values is envisaged and reduces inspection effort. Plan standard values as a fallback and document inquiries and assumptions. - We have already invested in reporting/IT – is it still worth it?
Yes. Data quality, processes, and governance remain competitively relevant (customers, banks, procurement). Investments should be made modularly to efficiently implement adjustments to final ESRS/CSDDD outlines.
Download
DIHK Position on the EU Sustainability Omnibus (PDF, 329 KB) (only available in German)
- Relevant im Themenfeld:
- Nachhaltigkeit
- Schwerpunkte:
-
- Umwelt
- Bürokratie
Veröffentlicht 14.04.2025
Aktualisiert 13.03.2026
Kontakt
Kathrin Riedler
Referatsleiterin Europäische Umwelt- und Rohstoffpolitik
Dr. Rainer Kambeck
Bereichsleiter Wirtschafts- und Finanzpolitik, Mittelstand
Dr. Ulrike Beland
Referatsleiterin ökonomische Fragen der Energie- und Klimapolitik
Annika Böhm
Referatsleiterin Gesellschafts- und Bilanzrecht
Hauke Dierks
Referatsleiter Umwelt- und Rohstoffpolitik
Cornelia Upmeier
Referatsleiterin CSR | Sonderprojekte
Natascha Waltke
Referatsleiterin Wirtschaft und Menschenrechte