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EU – Council and Parliament reach provisional agreement on omnibus simplification package for CSRD and CSDDD – what has changed?
09 December 2025
At the end of November, trilogue negotiations opened. Now just a couple of weeks later the Council's presidency and the European Parliament negotiators have reached a provisional agreement on the omnibus simplification package for sustainability reporting and due diligence, amending the Corporate Sustainability Reporting Directive (“CSRD”) and the Corporate Sustainability Due Diligence Directive (“CSDDD” or “CS3D”). In this briefing we set out what the proposed amendments to the CSRD and CSDDD and what happens next.
On 9 December 2025, the Council’s presidency and the European Parliament negotiators reached a provisional agreement on the amended terms of the sustainability and reporting rules under the CSRD and the CSDDD. Read more on the previous steps of the process in our briefings here and here.
What has changed?
We have yet to see the text reflecting the amendments but from the press releases we understand that the CSRD scope, thresholds and amended terms are now expected to be:
- Scope: 1,000 employees and over €450 million net turnover
- Exemption: for financial holding undertakings
- Wave One companies that had to start reporting from financial year 2024: a transition exemption for 2025 and 2026 (and will not need to report)
- Review clause for 2031: for future possible extension of scope for both CSRD and CSDDD
- Sector specific reporting: voluntary
We understand that the CSDDD scope, thresholds and amended terms are now expected to be:
- Scope: 5,000 employees and €1.5 billion net turnover for EU companies; €1.5 billion net turnover in the Union for non-EU companies
- Climate transition plans: removed
- Transposition: pushed back one year to 26 July 2028 and compliance for companies is from July 2029
- Due diligence: Instead of limiting due diligence to tier 1, companies will take a risk-based approach along their chain of activities
- No EU wide civil liability: national rather than EU level and fines of up to 3%
Next steps
We await the final text for the amendments to get full clarity on the changes, this is expected on 10 December 2025. But in the meantime, COREPER is likely to vote on the provisional agreement on 10 December 2025 for EU Member States. The Legal Affairs Committee (JURI) will vote on the provisional agreement on 11 December 2025 then Parliament will vote as a whole on it in plenary session on 16 December 2025.
Our global ESG group brings together a multidisciplinary global team that provides clients with best-in-market support. We are following developments relating to ESG regulation, so please get in touch if you would like to discuss.
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This note is intended to be a general guide to the latest ESG developments. It does not constitute legal advice.
Authored by Christelle Coslin, Margaux Renard, Rita Hunter, Julia Cripps, Emily Julier, Christian Ritz, and Felix Werner.
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