30 September 2025

New Ceemet position paper on the Omnibus Package I on on CSRD and CS3D

Ceemet’s new position paper applauds the European Commission’s simplification agenda and the Sustainability Omnibus Package I. The overall reporting burden resulting from EU-level legislation is excessive and poses an unacceptably high administrative burden on EU-based companies. The industry needs streamlined and coherent reporting obligations that are proportionate and cover only what is strictly necessary to achieve a specific goal.

Ceemet welcomes the proposed simplifications in the scope of the CSRD and CS3D. Prioritising a risk-based approach and simplifying due diligence requirements are also essential to limit the regulatory burden and costs imposed by the CSRD and CS3D on companies. These changes are also important for improving the workings of the CS3D.

However, Ceemet calls for even better alignment and coherence among target companies across different legislations. First, Ceemet advocates for a further limitation in the scope of reporting entities and data points. Ceemet refers to its position paper on ESRS, where we call for a thorough overhaul and reduction of the data points in the European Sustainability Reporting Standards (ESRS) S1 “Own Workforce” and ESRS S2 “Workers in the value chain”.

In addition, Ceemet calls for maximising harmonisation and excluding entirely the possibility for Member States to add additional layers of requirements and accountabilities on companies, to guarantee a level playing field and consistency for companies across the entire EU.

Furthermore, there are still significant overlaps between sustainability reporting and due diligence obligations and other pieces of legislation. These overlaps should be eliminated by another omnibus procedure soon.

You can read these and other proposals in the full position paper via the link below:

For more, check out Ceemet’s earlier position on the draft European Sustainability Reporting Standards S1 and S2 published in May 2023.