Forum per la Finanza sostenibile
Comments regarding the proposals of the Omnibus package. Call for evidence on SFDR revision launched to collect stakeholders’ feedback
The proposed amendments to the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the Taxonomy Regulation included in the Omnibus Simplification Package published in February 2025 have sparked reactions from various stakeholders.
Positions on the Omnibus Package
Among those who have shared their views on the first Omnibus package, Eurosif has put forward several recommendations for European institutions ahead of the trilogue negotiations. Regarding the CSRD, Eurosif emphasises the importance of preserving the double materiality approach and suggests some adjustments to the proposed new scope of application, with different requirements based on the size of companies. They also urge institutions to convert sector-specific European Sustainability Reporting Standards (ESRS) into voluntary guidelines rather than abolishing them altogether and recommend allowing the collection of information from companies currently exempted from reporting obligations. On the CSDDD, Eurosif calls for maintaining the obligation to implement transition plans and reinstating the European civil liability regime. Concerning the Taxonomy, they propose aligning its scope with the CSRD and lowering the materiality exemption threshold to 5%.
Another significant comment comes from the European Central Bank (ECB), which, in its official opinion, highlights the critical role of the CSRD, Taxonomy, and CSDDD in risk management. The ECB specifically advises against narrowing the CSRD’s scope, suggesting instead simplified standards for mid-cap enterprises. It also stresses the need to maintain the datapoints required by ESRS E1 on climate and ESRS E4 on biodiversity, as these are vital for assessing credit exposure to physical and transition risks. Regarding the CSDDD, the ECB underscores the importance of ensuring the actual implementation of transition plans along with their annual review.
Finally, the United Nations Office of the High Commissioner for Human Rights (OHCHR) has published its position, focusing particularly on the proposed amendments to the CSDDD. According to its assessment, any changes to the directive should ensure alignment with international standards, such as the OECD Guidelines for Multinational Enterprises and the International Labour Organization (ILO) standards, whereas the proposals in the Omnibus package risk causing misalignment. The OHCHR also highlights that due diligence could become a reactive rather than a preventive process, especially if the new focus is limited only to tier 1 of the value chain. Another concern raised is the potential for regulatory fragmentation and inconsistency resulting from the removal of the European civil liability regime.
Revision of the SFDR Regulation
Regarding the revision of the Sustainable Finance Disclosure Regulation (SFDR), the European Commission has collected comments and suggestions from stakeholders through a Call for Evidence. The Commission hopes that the revision will enhance legal clarity and ensure overall consistency within the sustainable finance regulatory framework, including proposed measures to simplify sustainability disclosures for companies.
Guidelines for supervisory authorities
The latest update comes from the European Securities and Markets Authority (ESMA), which has published guidelines for implementing sustainability disclosure rules. These guidelines aim to prevent greenwashing, harmonise supervisory practices, and ensure reliability and comparability, thereby contributing to investor protection and market stability. These guidelines apply to all authorities overseeing sustainability information under the Transparency Directive (Article 24(4) of Directive 2004/109/EC). Key aspects addressed include effective implementation processes, independence of involved parties, selection of supervised entities, timelines, types of controls, identification of significant violations, enforcement measures, and sanctions.
