With the omnibus package (COM(2025) 80, 81, 87), the EU Commission aims to make reporting obligations (CSRD/ESRS), due diligence obligations (CSDDD), and carbon border adjustment (CBAM) leaner and more manageable. For companies, it's about reducing bureaucracy, clearer scopes of application, and reliable deadlines. Positive aspects include higher thresholds for CSRD, a value-chain cap using VSME standards, options in taxonomy, and a 50-tonne allowance for CBAM. Crucial now is a rapid adoption with practical transition rules - so that investments in transformation and competitiveness are not slowed by uncertainty.
Summary at a Glance
- CSRD: Reliefs planned (including a threshold of 1,000 employees and removal of sector-specific ESRS), Value-Chain-Cap via VSME.
- CSDDD: Partial harmonisation, fewer bureaucratic obligations, yet still requirements for plausible risks in deeper chains.
- Taxonomy: Voluntary reporting for parts of the companies; simplified reporting templates announced.
- CBAM: 50-ton exemption limit, standard values, additional anti-avoidance regulations – registry obligation remains a critical issue.
- Urgent: swift resolution, clear transitional rules and coherence between CSRD, CSDDD, financial supervision and customs procedures.
Background
Environmental legal requirements often cause high costs, additional reporting and documentation obligations, as well as long and complex approval processes. Many regulations are based on EU law and are implemented inconsistently across member states, straining the single market. The EU Commission has announced an "environmental omnibus" for Q4/2025 and aims to simplify compliance with extended producer responsibility. Furthermore, there are significant potentials for standardization, relief, and clarity in other legal acts - such as EUDR, PPWR, IED, RoHS, WEEE, Single-Use Plastics Directive, and UVP/IE procedures. The DIHK proposes concrete adjustments that preserve environmental protection goals while avoiding excessive bureaucracy.
What is important for companies
- Examine scope of application: Will your company be subject to CSRD only from 1,000 employees? Check deadlines (expected from fiscal years 2027/2028) and prepare materiality analyses, processes, and systems in time.
- Focus on supply chain: Streamline queries along the chain and - as soon as available - use the VSME basic module as the standard for data requirements from non-reporting SMEs (once-only principle, consider interfaces to ERP/reporting tools).
- Optionally use taxonomy reporting: Where permitted, reduce efforts; at the same time, structure internal data pools so that a later expansion is possible without media disruption.
- CBAM preparation: Consolidate import volumes of CBAM goods, check 50-tonne limit per year, explore availability of emission data, and plan standard values as fallback; standardize processes with customs service providers.
- Planning for audits and IT: Account for adjustments due to ESRS revisions (data models, controls, audit-readiness), but stagger investments - depending on timing of legislation and national implementation.
DIHK demands
- Legal certainty: Suspend sanctions for the "first wave" of CSRD retroactively and adopt clear transition rules; apply revised ESRS with sufficient lead time.
- Focus CSRD: Consistently design thresholds to be practical; effectively limit value-chain requirements (Tier‑1 focus), define VSME bases as binding cap, and interpret them coherently across Europe.
- Ensure coherence: Coordinate financial supervision (guidelines/reporting standards of institutes) on VSME bases; recognize international standards (including ISSB) interoperably; review necessity of ESEF obligations.
- Targeted CSDDD: Clearly and measurably define core rights/prohibitions; "white list" for countries with high protection standards; proportional and consistent liability and sanction regime across Europe.
- Practical CBAM: Choice between registration and certificate trading and simplified customs accounting based on standard values; promptly decide on 50‑tonne allowance, regularly evaluate standard value methodology.
FAQ
Frequently Asked Questions
- When do the relief measures take effect?
As long as the Council and Parliament have not adopted and published the proposals, the current obligations remain in force. Companies should plan with scenarios and observe transitional rules. - What is the VSME standard and what is it used for?
The voluntary SME standard (VSME) aims to provide a uniform, streamlined data set for sustainability inquiries along the chain – as a 'cap' for supplier inquiries and to relieve non-reporting SMEs. - Does the 50-tonne limit on CBAM affect me?
Add up the annual quantities of CBAM-liable goods (per importer). Importers are exempt below 50 tonnes. In borderline cases, clarify processes with customs service providers early. - What if suppliers do not provide emissions data?
The use of standard values is foreseen and reduces audit 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 requirements.
Download
DIHK statement on EU sustainability omnibus (PDF, 329 KB)(only available in German)
- Relevant in topic:
- Nachhaltigkeit
- Key areas:
-
- Umwelt
- Bürokratie
Released 14.04.2025
Modified 18.02.2026
Contact
Kathrin Riedler
Director European Environment and Raw Materials Policy
Dr. Rainer Kambeck
Managing Director Economic and Financial Policy, SME
Dr. Ulrike Beland
Director Economic Aspects of Climate and Energy policy
Annika Böhm
Director Corporate and Accounting Law
Hauke Dierks
Head of Environmental and Resource Policy
Cornelia Upmeier
Director CSR | Special Projects
Natascha Waltke
Director Economy and Human Rights