EU Omnibus Package: Key Takeaways & Impacts on CSRD
Leah (Foertsch) O'Neill
March 25, 2025
Savannah Rodrigue
March 25, 2025
This action is significant and wide-ranging, affecting technical scoping and data points, reporting obligations, and compliance timelines. Here’s an overview of what you need to know from Principal Consultant Leah (Foertsch) O'Neill and Sustainability Advisory Senior Consultant Savannah Rodrigue from Arcadis.
Key Impacts on CSRD:
- Scope: Only very large companies (>1,000 employees AND >€50M turnover or >€25M assets) would be subject to reporting requirements, cutting out 80% of companies originally in scope.
- Threshold: Non-EU parent companies would need ≥€450M EU turnover to fall in scope, and the EU branch threshold aligns to €50M, matching the “large” company size. This is only about 900 companies globally.
- Start dates: Companies originally due to start reporting in 2026 (FY 2025) and 2027 (FY 2028) would receive a 2-year delay.
- Reporting standards: Sector-specific requirements would be removed and the planned upgrade to reasonable assurance would be cancelled (limited assurance would stay).
- Data points: The number of mandatory ESRS data points would be substantially reduced.
Next Steps Companies Should Consider Taking:
- Companies affected by these changes should assess their reporting obligations, compliance timelines, and due diligence responsibilities to prepare for the new regulatory landscape. Companies should continue to prepare for the EU’s
corporate sustainability reporting requirements to strengthen their business resilience and create value.
- For CSRD, we recommend that large EU (wave 2) & non-EU (wave 4) companies stay the course and focus on preparing to report. If anything, potential delays in timelines should provide companies with more time to prepare and enhance
their data management and reporting readiness instead of rushing the process.
- For companies that are currently in an unclear position, such as small and medium enterprises (SMEs), it would likely be difficult to stop the process and start again; keep in mind that a restart is coming unless you fall out of the
thresholds. It is important to confer internally with your legal, finance, and executive leadership to determine your risk appetite for continuing preparation for reporting versus waiting for timeline updates.
- If your company were to fall out of the required threshold, we recommend that you consider continuing to focus on the CSRD components that provide strategic value to your business, such as conducting double materiality assessment to assess your business strategic priorities and embedding sustainability in your business strategy and functions.
Learn More at TECH25
At TECH25, Leah and Savannah are leading a GHG & CSRD Data Management Bootcamp. Participants will walk away with a better understanding of:
- Complex CSRD regulatory requirements
- The current EU Omnibus Proposal
- Basics for applying GHG measurement and accounting to your business
- Digital strategies to automate and transform your sustainability reporting needs
- The current state of the sustainability software market
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About the Author
Leah (Foertsch) O'Neill
Arcadis
Leah Foertsch is a Principal Consultant with 15 years of experience specializing in Environment, Health, Safety, and Sustainability (EHS) consulting and software implementation services. She leads the Digital EHS Strategic Advisory practice at Arcadis,
guiding customers through current and future state process analyses, technical requirements elicitation, vendor selection support, implementation planning, and program roadmap development. Her expertise spans a variety of domains including mining, oil
and gas, life sciences, manufacturing, and hospitality. Leah is passionate about organizational change management and recognizes the importance of focusing on people to drive business transformation.
Savannah Rodrigue
Arcadis
Savannah is a Senior Consultant on the Arcadis NA Sustainability Advisory Team with 7 years of experience in sustainability and environmental regulatory policy. Savannah has cross-sector and industry experience in GHG accounting, Climate Risk & Reporting,
Decarbonization Strategy, and ESG disclosure (CDP). She also has specialized experience in implementing GHG accounting software, developing credible Climate Transition Plans for transportation and service-based companies, and conducting climate transition
risk and opportunity assessments. Savannah holds a Master of Public Affairs (MPA) in Environmental Policy Analysis and Natural Resource Management from Indiana University-Bloomington and a BS in Environment & Society and Political Science with a Minor
in Economics from Florida State University.