Background 

The EU Green Deal has been subject to ongoing negotiations and revisions. As part of this trend, several initiatives have been launched to revisit existing EU sustainability legislation, including the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Taxonomy Regulation (EU Taxonomy).

On 26 February 2025, the EU Commission published two Omnibus packages (please be referred to our earlier blog).

On 3 April 2025 and 16 April 2025, the EU legislators endorsed, via a fast-track procedure, the first Omnibus ‘stop the clock’ proposal to postpone some reporting deadlines under the CSRD and CSDDD (please be referred to our earlier publication). With the formal adoption of the First Omnibus ‘stop the clock’ proposal, the entry into application of the CSRD requirements for large undertakings that have not yet started reporting is postponed by two years, and the transposition deadline and first phase of the CSDDD is postponed by one year.

The second Omnibus aims to reduce the burden of the CSRD and the CSDDD by at least 25%. This includes simplifying sustainable finance reporting and due diligence requirements to support the European Green Deal’s goals.

Final Position of the Council on the second Omnibus adopted on 23 June 2025

The Council adopted on 23 June 2025 its final position on the second Omnibus proposal (the Council’s Final Position). The Council’s Final Position constitutes, in essence, a formal response to the second Omnibus proposal as submitted by the EU Commission on 26 February 2025. The Council’s Final Position broadly aligns with the EU Commission’s proposal in respect of both the CSRD and the CSDDD (please be referred to our earlier publication).

Anticipated Final Position of the EU Parliament endorsed on 13 October 2025 

As the legislative process advances, the EU Parliament was expected to adopt its final position imminently. After several rounds of negotiation, on 8 October 2025 a majority agreement was reached on a key compromise package – the Anticipated Final Position (please be referred to our earlier publication). On 13 October, the Legal Affairs Committee (JURI) formally endorsed this compromise.

EU Parliament blocked mandate to commence trilogue negotiations on basis of Anticipated Final Position on 22 October 2025

However, contrary to expectations, the EU Parliament has voted against the mandate to take this Anticipated Final Position directly into trilogue negotiations.

As a result, the Omnibus will return to the next plenary session (scheduled for 11–13 November 2025) for a full vote. A new deadline for amendments will be set, potentially involving new amendments to the Anticipated Final Position on the CSRD and CSDDD (please be referred to our earlier publication). The trilogue negotiations between the EU Parliament, the Council, and the EU Commission, originally planned to commence on 24 October, are now postponed. The aim remains to reach a final agreement on the second Omnibus by the end of 2025 or early 2026, but the timeline is now under pressure and the legislative outcome of the second Omnibus remains uncertain.

Still to come

The rejection of the trilogue mandate has injected fresh uncertainty into the legislative trajectory of the CSRD and CSDDD. While the Anticipated Final Position reflected broad convergence with the Council, the upcoming plenary session in November – and the likelihood of new amendments being tabled – could significantly alter the scope, timing, and ambition of the second Omnibus package.

In short: the anticipated reduction and simplification of sustainability obligations under the CSRD and CSDDD, once considered politically settled, is now back on the negotiating table. The legislative process has entered a new and unpredictable phase, and the final shape of the reforms remains open.

We are closely monitoring these developments and will provide a further update following the November plenary session, should new amendments or political shifts warrant renewed analysis.

Get in touch

For tailored advice or further information about the implications of the CSRD, CSDDD, or the second Omnibus, please feel free to contact one of our colleagues below.