[Position paper] Views on the Omnibus Package I on CSRD and CS3D

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26 September 2025

Ceemet applauds the European Commission’s simplification agenda and welcomes the Sustainability Omnibus Package I. There is now a unique window of opportunity to recalibrate and embrace the simplification and alignment of a multitude of European Directives, Regulations, and Acts. Cutting down on the multi-layered sustainability reporting bureaucracy will enhance the economic competitiveness of our European companies. Only competitive companies can create jobs and thereby maintain the AAA of Social Europe on employment and working conditions.

Given the unpredictable current geopolitical and economic climate, the simplification package on sustainability reporting, aiming to review EU rules to enhance competitiveness and attract investment, should reduce the administrative burden for companies. Ceemet, therefore, supports the swift adoption of the “Stop-the-clock” Directive on 14 April 2025, postponing the application of all reporting requirements in the Corporate Sustainability Reporting Directive (CSRD) and postponing the transposition deadline of the Corporate Sustainability Due Diligence Directive (CS3D). This postponement allows the minimum time needed to amend the CSRD, CS3D and Taxonomy Regulation, even if a further postponement of the CS3D directive until 2029 would also be necessary, as proposed by the EU Council.

The Commission’s proposed amendments to these pieces of legislation should simplify and lessen the administrative burden of companies, whilst maintaining commitments to their overall policy objectives. For coherence and compliance reasons, simplification of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector should also be considered.

Whereas the proposed changes are indeed a step in the right direction, Ceemet believes that there remains room for further improvement. In line with the previous position papers of Ceemet, it is vital that additional measures are taken to ensure the proportionality and effectiveness of the legislation in question.