The Sustainability Omnibus has led to substantive amendments to the EU CSRD, EU CSDDD, and EU Taxonomy, bringing clarity on next steps.
By Michael D. Green, Betty M. Huber, David Little, James Bee, and Toon Dictus
On December 2025, after months of negotiation, the EU finalised Directive 2026/47, also known as the Detailed Omnibus Directive (Detailed Directive), which forms part of the first Omnibus package on sustainability. The Detailed Directive has resulted in substantive amendments to both the EU Corporate Sustainability Reporting Directive (CSRD) and the EU Corporate Sustainability Due Diligence Directive (CSDDD). Following formal endorsement from the European Council, the Detailed Directive was published in the Official Journal of the EU on 26 February 2026 and came into force on 18 March 2026.
The Detailed Directive materially amends the scoping for both the CSRD and CSDDD, resulting in focusing sustainability disclosures and related conduct obligations on the largest entities. It raises the CSRD thresholds so that mandatory reporting will apply only to EU companies with over 1,000 employees and €450 million net annual turnover (with separate, tailored rules for non‑EU groups). In parallel, the CSDDD is refocused on only the largest companies, accompanied by the much-lobbied removal of the proposed obligation to adopt a climate transition plan, penalties for non-compliance being capped at 3% of worldwide turnover, and deferred application by one year to July 2029. Together, these changes are aligned with the EU’s drive to simplify regulations and to increase competitiveness by reducing burden for businesses, and the Commission’s perspective on preserving sustainability objectives.
For more information, see this Latham article.