17/11/2025
Insights Blog

The European Parliament has adopted its negotiating position on the Commission’s Omnibus I proposal amending the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). According to the Parliament’s press communications, the approach endorsed by MEPs narrows scope, shifts due diligence towards a risk‑based model and removes mandatory transition plan obligations.

Key aspects include:

  • CSRD scope – raising the thresholds so that mandatory sustainability reporting applies to EU companies with more than 1,750 employees and net turnover above EUR 450 million, aligning with the Council’s turnover threshold. This would further reduce the number of in‑scope companies relative to the Commission’s proposal.
  • CSDDD scope – confining due diligence obligations to very large companies, with at least 5,000 employees and net turnover of EUR 1.5 billion, consistent with the Council’s position. As CSDDD scope for non-EU companies is determined by reference to turnover within the EU (without an employee threshold) it is anticipated that the Parliament’s proposed increased threshold would apply to non-EU companies on this basis, but this is not confirmed in the press release.
  • Climate transition plans – deletion of the mandatory requirement for climate transition plans under CSDDD, leaving the nature of any transition plan obligation to be settled during trilogues.
  • Due diligence – a risk‑based model for due diligence under CSDDD, rather than the Council’s emphasis on tier‑one business partners. This aspect is expected to be a focus of negotiations with the Council.
  • Civil liability under CSDDD – liability for breaches of due diligence obligations would be addressed under Member State law, rather than via a harmonised EU regime.

Trilogue negotiations are expected to start on 18 November, with co-legislators aiming to agree the final legislative text before year-end.