Status: Adoption pending
As a key part of the EU’s Competitiveness Compass, the Omnibus I Simplification Package – approved in December 2025 – aims to streamline corporate sustainability reporting by introducing changes to:
During the legislative process, some businesses that have already invested significantly in compliance have expressed reservations about the proposed adjustments. Companies like Primark, L’Occitane, Nestlé, and NEI Investments are urging the Commission not to weaken sustainability reporting standards, warning that such changes could undermine business certainty and investment.
However, the Commission emphasizes that Omnibus I aims to simplify sustainability reporting across Member States while preserving core environmental objectives. As a result, the legislation remains focused on the largest brands, which account for the majority of environmental impacts.
Let’s dive in to see what these changes mean for apparel and footwear brands.
CSRD: Only brands with more than 1,000 employees and over €450 million in annual net turnover are required to report on sustainability.
CSDDD: Due diligence obligations apply only to brands with over 5,000 employees and more than €1.5 billion in annual net turnover.
A digital portal will provide standardized templates and guidance to support businesses with reporting requirements.
In EU policymaking, “omnibus” is commonly used as shorthand for legislative simplification. The European Commission regularly introduces multiple omnibus packages, each addressing a different policy area and numbered separately. For example, Omnibus VI focuses on simplifying EU chemical legislation, while Omnibus II targets the simplification of EU investment frameworks.
Omnibus I sits within this broader simplification agenda and focuses on corporate sustainability reporting and due diligence, with the objective of simplifying EU sustainability rules, supporting competitiveness, and reducing administrative burdens for brands.
The package was approved through the EU’s formal legislative process in December 2025, introducing legally binding changes to existing sustainability legislation, including the CSRD and the CSDDD.
The Council of the European Union is expected to give final approval in early 2026, a formal step that will allow the amendments to enter into law. Under the proposal, Member States will have to transpose the Directive into national law by July 2027.
(Note: Original Omnibus package referenced adjustments to CBAM and EU Taxonomy; however, the current political agreement covers only CSRD and CSDDD.)
Learn all about the Corporate Sustainability Reporting Directive requirements for apparel and footwear here.
Reporting Frequency: Brands must report on their due diligence measures every four years, rather than annually.
Learn all about the Corporate Sustainability Due Diligence Directive for apparel and footwear brands here.
As part of the EU’s Omnibus I Simplification Package, the Stop-the-Clock mechanism was adopted in April 2025, delaying the application of certain CSRD and CSDDD requirements.
While the CSRD was initially introduced through a wave-based rollout, Omnibus I simplifies this by limiting CSRD to a smaller group of companies defined by clear employee and turnover thresholds – meaning brands with more than 1,000 employees AND over €450 million in net annual turnover remain in scope.
*You may already be aware of the Non-Financial Reporting Directive (NFRD), which introduced similar reporting requirements in the EU. These were deemed insufficient, and in 2021, the CSRD replaced and expanded the NFRD's reporting requirements.
Important to note: Brands with fewer than 1,000 employees or less than €450 million in net annual turnover fall outside of the CSRD scope and do not need to report. E.g., a fashion brand with 900 employees and €600 million in net annual turnover -> not in scope.
After Omnibus I, only one group of very large companies is subject to mandatory due diligence obligations.
Who: Companies with more than 5,000 employees and over €1.5 billion in global turnover.
When: Implementation of CSDDD into national law has been postponed by one year. This means brands will first be required to comply with due-diligence obligations in 2029, covering activities carried out in 2028.
While brands technically have until 2028/2029 to comply with the CSRD and the CSDDD, waiting until the last minute to decide on a solution significantly increases the risk of non-compliance.
Waiting until closer to the deadline leaves limited time to gather and clean upstream data – a process that typically takes at least a year. Supplier data is often incomplete or inconsistent, and you may need to integrate complex systems like Product Lifecycle Management (PLM) to ensure full visibility. Rushing this work increases the likelihood of missing critical information and results in last-minute fixes that can be costly and inefficient.
By preparing your systems in 2026, you can avoid a rushed and expensive last-minute scramble. Getting ahead of the curve allows for smoother data collection, integration, and reporting processes, helping to ensure that you meet compliance requirements without compromising quality or accuracy.
The evolving EU regulatory landscape means brands must navigate different scopes, timelines, and reporting requirements under CSRD, CSDDD, and other frameworks. As thresholds change and new simplifications are introduced, understanding which rules apply – and generating accurate, audit-ready disclosures – becomes increasingly complex for sustainability teams.
Carbonfact's platform acts like a bridge that simplifies all these different rules and methods. It helps brands by automatically applying the right rules and methods for each situation, so they don’t have to worry about the complexity of dealing with different regulations from around the world.
Here’s how:
By getting started with our platform today, you're not just checking compliance boxes – you're gaining actionable insights that drive smarter decisions about your environmental impact, no matter when the reporting deadlines ultimately fall.