For the 2024 and 2025 financial years, it is confirmed that the first set of ESRS standards, combined with the quick-fix delegated act (officially effective from 13 November 2025), apply to all companies currently within the scope of the CSRD. Note that EFRAG has been asked to simplify the standards. The first consultation period has been completed, and the revisions are expected in early December 2025.
CSRD in motion: What the Omnibus period means for companies
1 december 2025
This blog is written by our jr. strategy consultant, Lars Aalders
CSRD in motion:
What the Omnibus period means for companies
In recent years, the EU has rapidly built a new sustainability framework. With the CSRD, the playing field changed fundamentally: many companies initially fell within scope, double materiality became the standard, and the ESRS introduced a far more detailed approach to reporting. From the 2024 financial year, the first organizations had to start reporting, followed by a larger group in 2025.
At the same time, political pressure increased. Especially in 2024 and 2025, it became clear that the pace of scaling was faster than many companies could manage, particularly smaller businesses and sectors with complex supply chains. To address this, the European Commission presented the Omnibus package: a set of simplifications designed to reduce administrative burdens and shift the focus to the very largest companies. The European Parliament and Council support this approach, although they still differ on the exact details. Ongoing trilogue negotiations will determine the final outcome, with a decision expected in early 2026.
We are therefore in a dynamic transition phase: the foundation is set, but the edges are still moving. For companies, it is crucial to understand where there is flexibility, what might still change, and where you need to keep momentum despite the uncertainty.
What could still change?
The trilogues will determine in the coming months how far the simplifications actually go:
- CSRD scope – the proposed higher threshold (>1,750 employees and €450 million turnover) is still just a proposal, not law.
- Transition plans – these could be reinstated in the final text.
- Assurance – may eventually shift from “limited” to “reasonable.”
- Sector-specific ESRS – currently off the table, but not definitively removed.
What is set in stone?
Despite political shifts, the core remains intact:
- CSRD remains European law for all companies already falling within the first two waves.
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- The VSME standard has been adopted as a voluntary framework for SMEs, allowing easier reporting within value chains.
As a retail company with >250 employees and >€50 million turnover, you currently fall under CSRD and report according to the simplified ESRS.
Next year, thresholds are likely to rise significantly, potentially removing your CSRD obligation; in that case, the voluntary VSME standard can be used, and Future Up’s VSME Readiness Check quickly shows your current position and next steps.
Whether or not you fall within CSRD scope, the demand for reliable ESG data will only continue to grow.
What this means for companies now
Political adjustments mainly change the conditions, not the direction. Transparency remains the norm, and value chains continue to rely on quality data.
Three practical implications:
- Data quality remains key
The quick-fix eases detail but not the need for robust data flows, clear responsibilities, and solid processes.
- Focus over completeness
Fewer mandatory data points create room to prioritize what truly matters: material themes and strategic impact.
- VSME becomes more important
As SMEs work with a voluntary standard, CSRD companies must organize data collection smarter, more consistently, and with a chain perspective.
Our advice for this phase:
Do not let political uncertainty slow you down:
Use this extra breathing room to build. Now that scope and regulatory details can still shift and the pressure is temporarily lower, this is the perfect moment to strengthen your foundation: refine your ESG strategy, deepen your materiality assessment, engage stakeholders more actively, and make data flows more robust. Governance, supply chain collaboration, and internal role allocation can also be carefully established now. Link this directly to concrete steps such as:
- ESG strategy & implementation
- Materiality assessment
- Stakeholder engagement
- Supply chain sustainability
- Certifications such as EcoVadis and B Corp
- Themes such as social impact and circularity
Prepare your narrative in advance:
Reporting is not just about compliance; it’s about the story your organization wants to tell: why certain themes truly matter, how decisions are made, and where the greatest impact is expected. By crafting this now in an inspiring and clear way and testing it internally, you build a solid compass that prevents costly adjustments later when pressure rises. Many organizations struggle not with data or technology, but with internal clarity on roles, priorities, and expectations. A clear, shared narrative provides direction, energy, and momentum for everything that follows.
Companies that invest now will be stronger tomorrow, both organizationally and strategically, and better prepared for future regulations.
