With the Omnibus negotiation process in progress, the EU Council circulated an updated draft proposal dated 17 June 2025 on key changes to #CSRD – key extracts:
Thresholds
Sustainability reporting obligations should be reduced to undertakings with a net turnover exceeding EUR 450 million and an average of more than 1 000 employees during the financial year.
Member States should be able to exempt undertakings that would subsequently fall outside of this scope, from reporting obligations as regards the financial years beginning between 1 Jan 2025 and 31 Dec 2026.
Value chain cap
Reporting undertakings should be prohibited from requiring information exceeding certain limits from undertakings in their value chain that have up to 1 000 employees, and these should be given a statutory right to refuse to provide information exceeding those limits.
To ensure proportionality, the scope of this ‘value-chain cap’ is limited in the following ways:
- It does not prohibit the sharing of information on a voluntary basis, such as information that is commonly shared in a given sector.
- It does not affect any obligation that may exist, whether contractually or under other Union or national law, to provide information that falls within the scope of the value-chain cap.
- The value-chain cap only applies to information gathering done for the purpose of reporting sustainability information as required by Directive 2013/34/EU.
- It does not affect Union requirements to conduct due diligence or information gathering made for any other purpose, such as for the reporting undertaking’s risk management.
It is important that reporting undertakings only request information from their value chain insofar as necessary.
In particular, it is important that they request less information than that specified in the standards for voluntary use (VSME) if they do not need all the information in those standards.
Permission to omit certain information
There are circumstances in which undertakings should, subject to assurance, be permitted to omit certain information from the sustainability report. Those circumstances should be developed and clarified. This includes:
- Information that could seriously prejudice its commercial position – in exceptional cases and provided that the interests of the users of sustainability reports are also adequately protected.
- Information such as intellectual capital, intellectual property, know-how or the results of innovation that would qualify as a trade secrets as defined in Directive (EU) 2016/943.
- Classified information.
- Information that is to be protected from unauthorised access or disclosure according to other Union legislation or national law.
- Information which would be prejudicial to the privacy of natural persons or to the security of natural or legal persons. This is especially important in the current geopolitical context.
Source: Omnibus update 17 June 2025
#getCSRDready, #CSRD, #ESRS, #ESG, #Strategy, #Governance, #SustainabilityReporting, #Digitalisation, #Cleerit