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On 13 November 2025 the European Parliament adopted its negotiating position on the proposed directive amending the EU Corporate Sustainability Reporting Directive...
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On 13 November 2025 the European Parliament adopted its
negotiating position on the proposed directive amending the EU
Corporate Sustainability Reporting Directive (CSRD) and the EU
Corporate Sustainability Due Diligence Directive (CSDDD), which
forms part of the Omnibus I Package (the
"Omnibus").
Some of the key details of the European Parliament's
proposal are set out below (in comparison to the other EU
institutions and the current text of the Directives).
Current text
Commission proposal
Council of the EU proposal
European Parliament proposal
CSRD applicable to "large companies"
and "parents of large groups" which have any two of the
following (individually or on a consolidated basis for the group):
Net turnover: >€50 million;
Balance sheet: >€25
million; and
Employees: >250.
A non-EU third country parent will also come into scope of CSRD
if it:
generates >€150 million net turnover
in the EU for each of the last two years; and
has either (1) an in-scope EU branch (itself generating
>€40 million annually) or (2) a large
in-scope EU subsidiary.
CSRD to be applicable at the same thresholds
for European companies as current text, however increase employee
average >1000.
For non-EU third country parent to be in scope
Net turnover: to be >€450 million;
and
Net turnover of an EU branch to be >€50
million.
However, no proposed change to the requirement for the
third-country undertaking to have a large in-scope EU subsidiary or
an in-scope EU branch, for it to fall within scope.
CSRD applicable to EU companies with
>1000 employees, and with €450
million in net turnover.
Same as the Commission proposal for third-country
undertakings.
CSRD to be applicable to EU companies with
>1,750 employees, and with
>€450 million in net turnover.
Non-EU parent undertakings with an EU branch or EU subsidiary
generating more than >€450 million in net
turnover.
CSDDD to be applicable to EU companies with
>1,000 employees and >€450
million in net worldwide turnover.
To non-EU companies with >€450 million
in turnover within the EU.
CSRD to be applicable at the same thresholds
for EU companies as current text but with an increase of the
average number of employees to be >1000.
To non-EU companies with >€450 million
in turnover within the EU.
CSDDD to be applicable to EU companies with
>5,000 employees and >€1.5
billion in net worldwide turnover.
To non-EU companies with >€1.5 billion
in turnover within the EU.
CSDDD to be applicable to EU companies with
>5,000 employees and >€1.5
billion in net worldwide turnover.
To non-EU companies with >€1.5 billion
in turnover within the EU
The European Parliament's proposal also includes significant
changes to CSDDD:
Deletion of requirement to have a transition plan from CSDDD,
with the requirement to disclose on existing transition plans
remaining in CSRD.
Requiring in-scope companies take a risk-based approach to
identifying and assessing adverse impacts, relying on information
which is already available and only requesting additional
information from their smaller suppliers as a last resort.
Removal of the specific EU-wide civil penalty provisions,
keeping civil liability only at the national level.
The three EU institutions will now move to trilogue negotiations
on 18 November 2025, which will involve a limited number of
representatives from the European Commission, the European
Parliament, and the Council of the European Union. These informal
negotiations aim to reconcile differing views and priorities and
expedite the legislative process, with the hopes of finalising the
negotiations by the end of the year.
In addition, the 'Quick Fix' Delegated Regulation was
published in the Official Journal of the EU on 10 November
2025, extending phase-in provisions under the current European
Sustainability Reporting Standards (ESRS) for companies who have
already been required to start reporting under CSRD
("Wave 1 companies"). The Delegated
Regulation applies retrospectively from 1 January 2025 and will
allow Wave 1 companies to continue taking advantage of various
phase-in provisions and transition relief measures that were
available in respect of reporting on 2024, for reporting years 2025
and 2026. As a result, Wave 1 companies will not be required to
report additional information in 2025 and 2026 beyond what was
included in their 2024 reports, to alleviate the burden of
reporting as these Wave 1 companies are not caught by the
'Stop-the-clock Directive' delaying the application of CSRD
for companies in scope not caught by Wave 1 (see our briefing on
the 'Stop-the-Clock Directive' here).
Finally, EFRAG has announced it will release its Draft Simplified
ESRS on 4 December 2025.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
