Implications of Omnibus I CSRD and CSDDD

The European Commission published the first Omnibus package on February 26. This comprehensive package includes several proposals to reduce administrative burdens that follow from the CSRD. The proposal limits the scope. The proposal provides for deferral for companies required to report as of fiscal years 2025 and 2026. A restriction is placed on requesting information from companies not subject to the reporting requirement by companies subject to the reporting requirement of the CSRD. Sector-specific standards will be removed. There will also be fewer data points to report on as a result of the proposals.

CSRD

The Netherlands is still in the process of implementing the CSRD, for which the implementation date is June 22, 2024. The Commission has started an infraction procedure for this, which
may have consequences, including a fine. On the relationship between the current proposals and the
implementation of the CSRD, the Cabinet is engaging in discussions with the Commission. The Proposal Postponement and Adjustments CSRD has implications for this implementation of the CSRD. The draft Implementation Decree Directive on Sustainability Reporting, which is still pending before the Senate, will then also be adjusted.

CSDDD

Currently, the CSDDD is being implemented in the bill International Corporate Responsibility Act (Wivo). An amendment to the CSDDD has consequences for this implementation process. Because the directive is going to be amended and can be amended by the Council and the European Parliament, an implementation proposal that gives the final picture of the obligations for companies cannot be drawn up at this time. In this regard, the proposal postpones the transposition deadline of the CSDD, from July 26, 2026 to July 26, 2027. However, this intended postponement does not alter the fact that at present, until the Proposal Postponing CSDDD formally enters into force, the transposition deadline of July 26, 2026 applies, and the Netherlands is still obliged to (continue to) implement CSDDD. Moreover, it cannot be predicted with certainty how long the negotiations on substantive amendments will take, which may make it difficult to meet the new transposition deadline.

In terms of content, a number of elements of CSDDD change that must be regulated at the national level.

Source: Letter accompanying information on new proposals European Commission, No. BZ2514394, Ministry of Foreign Affairs, March 24, 2025.

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