EU Omnibus Simplification Package: What It Means for CSRD, CSDDD and SMEs

What stays the same

The core architecture of CSRD and ESRS remains in place: companies in scope still have to report using ESRS standards and apply double materiality, and investors still get a standardized sustainability report alongside financials. The Omnibus also keeps the EU Taxonomy and CSDDD as key pillars of the broader sustainable finance and due diligence framework, rather than scrapping them.

Key CSRD changes in the Omnibus

The proposal mainly makes CSRD more targeted and less heavy for smaller firms.

• Narrower scope and higher thresholds: CSRD reporting would focus on larger companies (e.g., employee and turnover thresholds moving up), meaning some mid‑sized firms that were previously expecting to be in scope may now fall outside the mandatory perimeter.
• Delayed deadlines: Later implementation dates are proposed for companies that had not yet started reporting, including some 'Wave 2 and 3' filers and listed SMEs, giving them extra time to prepare.
• Lighter ESRS requirements: The package points to a reduction in the number of mandatory ESRS data points and removes the plan for sector‑specific ESRS in the near term, simplifying the reporting set‑up for companies that remain in scope.
• Voluntary standards for smaller businesses: Companies that end up outside CSRD scope could still use a lighter, voluntary ESRS‑based standard tailored to SMEs and very small entities, so they can respond to market pressure without full CSRD complexity.

Key CSDDD (CSDDD/CS3D) changes

For the due diligence directive, the Omnibus shifts focus toward practicality and reduced frequency.

• Later start dates: EU Member States would get an extra year to transpose CSDDD, and the first wave of obligations for the largest companies would move out by about a year as well.
• More targeted value chain checks: Companies would not have to conduct in‑depth assessments across every indirect business partner; instead, deeper checks are expected where there is credible risk of adverse impacts.
• Less frequent due diligence cycles: Due diligence assessments would move from annual to a multi‑year cadence (for example, every five years), reducing recurring administrative load while keeping a structured process in place.
• Eased pressure on SMEs: There would be clearer limits on what large companies can demand from SME suppliers, in many cases tying requests back to the voluntary CSRD standards designed for smaller firms.

What this means for suppliers and mid-market companies

The Omnibus is not a 'get out of ESG free' card; it is a recalibration. Many mid‑market suppliers may sit outside direct CSRD or CSDDD scope, but their large customers still need value‑chain data and due diligence evidence to satisfy investors, banks, and regulators.

• Fewer companies file full ESRS reports, but value‑chain data requests from in‑scope customers continue.
• Due diligence questionnaires may become more focused and less frequent, yet still require structured, evidence‑backed answers from suppliers.
• The competitive gap grows between suppliers that can respond quickly with consistent ESG data, and those still chasing numbers in spreadsheets and email.

How Complezy helps in an Omnibus world

Complezy is built for exactly this situation: suppliers and mid‑market companies that may not file a full CSRD report, but must keep delivering reliable ESG data to customers.

Even if the Omnibus shifts your company outside mandatory CSRD scope, you can still use Complezy to look organized, low‑risk, and responsive to your largest customers.

• Centralize ESG data once for emissions, workforce, and governance in a structured workspace instead of scattered spreadsheets.
• Respond to multiple CSRD‑ and CSDDD‑driven questionnaires by uploading customer templates and letting Complezy map questions to your existing data for fast, consistent answers.
• Attach evidence (policies, certifications, audits) directly to answers so your customers have what they need for ESRS disclosures and due diligence files.