The European Parliament’s recent position on amendments to the CSRD and CSDDD signals a significant recalibration of the EU’s sustainability regulatory framework. As these proposals progress through the Omnibus I Package negotiations, undertakings will face evolving expectations on reporting scope, due diligence and governance. Businesses will need to remain attentive and prepared to adapt their compliance processes to meet these emerging requirements.
On 13 November 2025, the European Parliament (EP) adopted its negotiating position on proposed amendments to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), forming a central component of the Omnibus I Package, and are expected to influence the compliance environment for businesses across the EU and beyond. As negotiations between the highest of institutions continue, companies increasingly will need to interpret and navigate these evolving regulatory expectations.
The Parliament’s proposed revisions seek to streamline the scope of the CSRD by raising the thresholds for in-scope EU companies. Under this approach, the CSRD would apply to undertakings with more than 1,750 employees and generate more €450 million in net turnover, with the former Statement of Financial Position criteria removed.
Non-EU parent undertakings would be brought into scope where an EU branch or subsidiary generates more than €450 million in EU net turnover. Although this narrows the number of companies directly captured, those that remain subject to the directive will face increasingly detailed reporting obligations under ESRS. This is precisely where CLA Malta, could come in and help businesses assess whether the revised criteria apply to them, performing gap analyses against existing reporting processes, and assisting with the design of governance structures and data-collection systems that ensure accuracy and consistency in future sustainability statements.
As important changes were proposed by the EP also to the CSDDD, which align broadly with the Council’s preference for significantly higher applicability thresholds. Under this approach, the CSDDD would apply to companies with more than 5,000 employees and over €1.5 billion in turnover within the EU. Further modifications include the removal of a mandatory transition plan requirement and a clearer focus on a risk-based approach to identifying adverse impacts within value chains. Businesses will need to maintain rigorous documentation and oversight to demonstrate compliance and accordingly need to develop due diligence policies to assess suppliers appropriately on an ongoing basis.
Additional developments under the Omnibus Package are also pertinent for companies currently preparing their sustainability reporting. The ‘Quick Fix’ Delegated Regulation, extends the existing transitional reliefs for Wave 1 Companies[1] already reporting under CSRD. Applying retrospectively from 1 January 2025, the regulation enables these companies to retain their existing phase-in measures for the 2025 and 2026 reporting years, meaning no additional reporting obligations beyond those undertaken for their 2024 sustainability statements.
As trilogue negotiations advance, it is clear that the Omnibus directive will shape the trajectory of EU sustainability regulation for the years ahead. For undertakings, these developments underline the importance of forward-looking preparation, sound governance structures, and robust data processes. CLA Malta stands ready to support organisations at every stage of this transition – from interpreting regulatory changes and assessing applicability, to designing reporting frameworks, enhancing due-diligence processes, and preparing ESRS-aligned disclosures.
“Let us assist you in embedding sustainability within your broader governance and strategic considerations, ensuring that you remain both compliant and resilient within an evolving regulatory landscape. From assessing applicability to strengthening reporting and due-diligence processes, we provide guidance and support to ensure your business remains prepared, resilient, and well-positioned for the challenges and opportunities ahead.”
How can CLA Malta assist you?
- Gap Analysis and Readiness Review
- Design and Implementation of Reporting Frameworks
- Assistance with ESRS Reporting and Disclosure Preparation
- Strategic ESG Advisory
Ancillary Services
- Transaction Advisory
- Company Valuations
- Financial Projections & Analysis
- Restructuring & Turnaround
- Project Management
- Risk Management Advisory
- Mergers & Acquisitions Reporting & Analysis
- Procurement & Tender Assistance
- Financial Feasibility Reports
[1] Wave 1 undertakings are the first group of companies required to report under the CSRD. They include large EU public-interest entities—such as listed companies, credit institutions, and insurance undertakings—with more than 500 employees, as well as non-EU companies listed on EU regulated markets meeting the same criteria. These entities began reporting for financial year 2024, with their first sustainability statements published in 2025.