Omnibus I package published in the Official Journal of the European Union
The European Parliament approved the Omnibus I package on December 16, 2025. On February 24, the Council of the European Union followed suit, and on February 26, it was published in the Official Journal.
What exactly means “Omnibus I”?
Omnibus I comprises amendments to the EU Supply Chain Due Diligence Directive (CSDDD), the Sustainability Reporting Directive (CSRD), the Taxonomy Regulation, and the Carbon Border Adjustment Mechanism (CBAM).
The amendments to the CSDDD and CSRD are divided into two packages. The first package of amendments is called “Stop the Clock” and has been in force since April 17, 2025. It regulates a postponement of the scope of application and the national implementation deadline in order to give member states and companies time to prepare for the upcoming changes. For example, the deadlines in the CSDDD for member states and companies are postponed by one year.
The second package contains further changes to the CSDDD and the CSRD. With the final approval of the Council of the European Union and publication in the Official Journal, the European legislative process is now finished.
What are the most important changes in the CSDDD?
Originally, the directive was intended to apply to companies with more than 1,000 employees and EUR 450 million in global net turnover. This threshold has now been raised to more than 5,000 employees and EUR 1.5 billion in turnover. In addition, civil liability has been abolished in its original form with EU-wide standardized requirements. The obligation to establish a climate plan has been completely removed from the CSDDD. However, the climate plan remains relevant in the context of sustainability reporting under the CSRD. The frequency of the internal monitoring of the adequacy and effectiveness has been increased from 12 months to at least every 5 years. It should be noted, however, that occasional monitoring, for example due to significant changes, remains necessary. In terms of sanctions, the maximum amount for a penalty payment has been reduced from at least 5% of global net turnover to exactly 3% of global net turnover. Finally, the harmonization of the directive has been extended, narrowing the scope for implementation by member states.
What happens next?
The German legislature must now transpose the amendments to the CSRD, CSDD, and Taxonomy Regulation into national law. Under the CSDDD, a deadline of July 26, 2028, has been set for the implementation in national law. – by adopting the German Supply Chain Due Diligence Act (LkSG) to the directive or by enacting a new law.
What changes are coming to the German Supply Chain Due Diligence Act?
While the LkSG focuses on direct business partners, the EU directive takes a risk-based approach in line with the UN Guiding Principles on Business and Human Rights. It follows that in the future, human rights issues and environmental compliance will play a greater role at the typically risky beginning of the supply chain, e.g., the mining of cobalt or lithium. Another new aspect is the obligation to provide remediation, how this will be implemented in practice remains to be seen. In addition, stakeholder participation is more strongly emphasized in the CSDDD and must be tightened up accordingly. If a company decides to terminate its business relationship with a supplier, the concept of responsible leave will apply in the future. According to this concept, companies must mitigate the negative consequences on the human rights of those affected by the termination of a business relationship. In addition, the CSDDD lists ten additional relevant environmental conventions, thereby expanding environmental due diligence obligations. These are a few examples of changes and are not an exhaustive list.
