The Act of 6 December 2024 amending the Accounting Act, the Act on Statutory Auditors, Audit Firms and Public Oversight, and certain other acts was signed by President Andrzej Duda and published in the Journal of Laws (Dz.U. 2024, item 1863) on 12 and 17 December 2024, respectively. As Poland, fortunately—though with a six-month delay—completes the process of implementing the CSRD directive, a new initiative appears on the EU horizon: the Omnibus.

Omnibus – What is it and why was it proposed?

Announced in November 2024 by European Commission President Ursula von der Leyen, the Omnibus is intended to be a “consolidated” legislative instrument aimed at simplifying administrative procedures and reporting requirements under the Corporate Sustainability Due Diligence Directive (CS3D), the Corporate Sustainability Reporting Directive (CSRD), and the Taxonomy Regulation.

The Omnibus is a European Commission initiative and a response to calls from member states and industry representatives to reduce the administrative burden associated with complying with the above-mentioned legal acts, particularly as many member states failed to implement the CSRD into national law on time.

The Omnibus instrument aims to bundle multiple legislative proposals into a single legislative package that can be adopted through one vote, significantly streamlining and simplifying administrative procedures. However, it is important to clarify that the proposed Omnibus for sustainable development will not merge CSRD, CS3D, and the Taxonomy Regulation into a single law (despite some sources interpreting the Commission President’s words as such). Instead, the resulting document will be a single legal act introducing amendments to each of the CSRD, CS3D, and the Taxonomy Regulation individually, which will still be understood and implemented separately.

Objectives:

• Reducing bureaucracy and simplifying requirements. The Commission aims to alleviate burdens by eliminating unnecessary and often overlapping regulatory requirements and simplifying rules, with the goal of:
• Enhancing the competitiveness of European companies in the global market. The proposal to simplify EU sustainability rules comes in the context of the European Commission refocusing on the competitiveness of EU enterprises relative to their global counterparts (with reference here to the Mario Draghi report).

Implementation timeline, scope, and implications:

The European Commission is expected to publish the proposed package in February 2025, with further developments possible over the course of the year. For now, the scope and consequences remain unclear. Some industry representatives suggest that the simplification package could constitute a significant reform of the EU sustainable finance system, particularly in light of the focus on boosting competitiveness. Potential changes may include:

• Revisions to size thresholds for qualifying companies.
• Reduction in the number of data points in the European Sustainability Reporting Standards (ESRS), which underpin the CSRD.
• Fundamental revisions to provisions that industry stakeholders have found unworkable.

Equally strong are the views that the core obligations arising from existing regulations will remain unchanged.

Stakeholder concerns:

Some stakeholders fear that the legislative process may allow the European Parliament and Council to reopen discussions on more fundamental changes—such as the contents of reports, implementation timelines, and the scope of companies required to report. Additionally, ESG professionals warn that premature reduction of reporting requirements could disrupt ongoing preparations and compromise data integrity. They call for legal clarity and a focus on the straightforward implementation of EU sustainability reporting standards.² The Omnibus announcement triggered a strong reaction from those committed to preserving the scope and strength of the EU’s sustainability commitments. For example, in mid-December, a coalition of over 90 NGOs, companies, and associations published a statement expressing deep concern that the Omnibus could facilitate a weakening of this legislation.

Although the announcement of the Omnibus has increased uncertainty for businesses, it is recommended that preparations for CSRD, CS3D, and the Taxonomy Regulation continue as planned. The ESG Institute team is closely monitoring the situation and the developments that the Omnibus may bring.

Author: Anna Barbaruk (Project Manager at ESG Institute)

ESG Institute Sp. z o. o.

info@esginstitute.eu

Rondo ONZ 1,
00-124 Warszawa

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