The Impact of EU Omnibus on Regulation: Preparing for the Future
The evolving regulatory landscape, particularly with the release of the EU Omnibus simplification package, is reshaping how companies approach compliance and sustainability. The initiative aims to streamline and simplify sustainability reporting and due diligence requirements – with key changes to CSRD, EU Taxonomy, CBAM and CS3D – to reduce administrative burdens and compliance costs, while still meeting reporting obligations under the EU Green Deal. The Commission has urged co-legislators to prioritize the EU Omnibus Simplification Package and to consider fast-tracking its proposals. However, it is essential to recognize that these proposals will require time to navigate through the EU institutions and Member States before finalization and transposition. Despite the simplifications, the regulations still aim to collectively push organizations toward more responsible business practices, with a strong emphasis on climate, nature and human rights.
As companies look ahead, understanding the next steps and preparing for the evolving regulatory environment is crucial. The Omnibus package offers companies significant opportunities to advance their sustainability goals. This article will summarize the immediate actions organizations can take and highlight no-regret strategies that will position them favorably not only for compliance with future sustainability reporting requirements but also beyond.
No-regret actions
On June 25th 2025, the Federal Council decided to halt the revision of the Ordinance on climate disclosures until the European Union has decided on simplifications linked to the Omnibus proposal. The Federal Council will decide the next steps in early 2026.
The extended timeline offers companies a valuable opportunity to better prepare and strategically allocate their resources. By focusing on “no-regret actions”, companies can position themselves to thrive amidst uncertainty.
1. Future-proof sustainability strategy: Establishing a long-term reporting strategy that integrates sustainability into the overall business model ensures that organizations are prepared for regulatory changes while maximizing the impact of their sustainability initiatives.
2. Maintain materiality assessments: Keep assessing financial and impact risk. Identifying and prioritizing material sustainability topics ensures that organizations address the most relevant issues. Employ scenario analysis and actively engage stakeholders to enhance materiality assessments and inform strategic planning.
3. Strengthen governance and data integrity: Establish robust ESG data governance frameworks to ensure accuracy, reliability and traceability. Implement internal controls to improve data quality, providing greater assurance to administrators and investors that the disclosed information is trustworthy and can withstand scrutiny from stakeholders and regulatory authorities. This will foster market confidence in sustainability reporting.
4. Leverage technology: Review existing technology. Explore the development of technology-driven solutions to enhance core data capabilities to serve multiple use cases besides reporting, including supply chain engagement, data quality management, EHS, LCA/PCF and more.
5. Human Rights & Environmental Due Diligence (HREDD): Enhanced supply chain transparency regarding dependencies, risks and opportunities can allow companies to better navigate the transformation ahead. The priority areas for HREDD should be risk-based and focused on the most significant business impacts. These priorities should also be aligned with the outcomes of double materiality assessments (if available) and, conversely, any double materiality assessment should be informed by the due diligence performed and its respective findings. We further recommend aligning the general due diligence approach with sector-specific requirements, e.g., on deforestation, forced labor or conflict minerals.
6. Engage stakeholders: Actively involving stakeholders in sustainability discussions helps organizations understand their expectations and concerns and builds trust. This engagement leads to more informed decision making and strengthens the alignment of sustainability efforts with stakeholder priorities.
7. Evaluate scope and compliance implications: Assess whether your organization falls within the proposed thresholds, considering the extra-territorial implications for non-EU parent undertakings. If your company is excluded, consider the alignment of voluntary disclosures with the expectations of investors and stakeholders.
8. Align with voluntary standards and best practices: Organizations may choose to voluntarily adopt sustainability frameworks such as GRI, ISSB or TCFD. Maintain transparent ESG disclosures to uphold credibility with investors and stakeholders.