EU omnibus package on sustainability – something we don’t want to ride (yet)?

In February 2025, the European Commission proposed its "first omnibus package on sustainability", aiming at simplification and deregulation of the current sustainability (reporting) regime in the EU.

One important measure addresses the scope of companies falling under the CSRD, which should be considerably reduced by introducing a new threshold of 1,000 employees. However, the impact of this proposed threshold does not seem well analyzed.

To contribute to the ongoing discussions, this paper analyzes a sample of approx. 32,000 Austrian companies retrieved from the Orbis database. The effects of the omnibus proposal with regard to the number of companies being excluded from the scope of the CSRD are assessed. Special consideration is given to effects resulting from group exemptions as well as over different sectors.

The results underline that the reduction of companies subject to the CSRD reporting requirements might be considerable-and for a SME-dominated country like Austria arguably even more severe than expected by the European Commission.

Also, different sectors are effected in a way that is not consistent with a sector's sustainability impacts or other considerations.

It is suggested to either modify the threshold of 1,000 employees or-even better-to not set it outside of the Accounting Directive's three thresholds approach, i.e. not making this higher threshold a necessary prerequisite for reporting requirements but instead equally important as balance sheet total and net revenue. Also, an approach that better differentiates between sustainability impacts-e.g. by defining "high risk sectors"-would mitigate some of the limitations of the current proposals.View the paper on ESG.Guide.