The European Union has introduced significant adjustments to the implementation of the Corporate Sustainability Reporting Directive (CSRD) and its technical standards, the European Sustainability Reporting Standards (ESRS). These changes, set out in the so-called Omnibus Agreement, respond to the need to give companies more flexibility, ease their adaptation and ensure that the process of reporting ESG information can be rolled out in a phased and realistic manner.
The most relevant points of the reform are set out below:
Temporary halt in the development of the sectoral ESRS
One of the most notable announcements of the Omnibus Agreement is the two-year pause in the development of the sectoral ESRS, which were to provide specific frameworks for sectors such as construction, energy, food, automotive or financial services.
This pause responds to:
- the high technical complexity involved in designing detailed standards for each sector.
- the need to give companies more time to implement the existing general ESRS.
- concern about the administrative burden, especially for SMEs and non-listed companies that are indirectly exposed.
Despite the pause, companies will have to base their information on the current cross-cutting ESRS and apply the double materiality principle to determine which sectoral topics are relevant.
Adjustments to the CS3D: phased roll-out of due diligence
Omnibus II introduces significant amendments to the CS3D, the European legislation requiring companies to identify, prevent and mitigate human rights and environmental impacts across their entire value chain.
The official reference text is the proposal published on the EUR-Lex portal EUR-Lex – 52022PC0071 – EN – EUR-Lex, and legal sources such as ECIJA have explained the changes in depth. EU agreement on the Omnibus II package: simplification of the sustainability rules (CSRD and CSDDD)
The key points introduced by the package are:
- A gradual roll-out of the obligations, according to company size.
- Longer periods to implement control, traceability and risk management systems.
- A reduced burden for companies operating with very complex supply chains.
- Greater methodological flexibility to define which risks are priorities and how due diligence measures are evidenced.
This reform seeks to prevent the CS3D from becoming an operational obstacle, while maintaining the ambition of strengthening corporate responsibility for social and environmental impacts.
Transposition deadline in Spain
The CS3D establishes that all Member States have 2 years to transpose the directive from its official publication in the Official Journal of the EU (OJEU). This means that Spain will have a maximum of 24 months from that date to adapt it into national law.
As the final directive is still awaiting official publication, the exact deadline will depend on when it enters into force. But the legal framework is clear and verified: two years of leeway, with no exceptions.
Temporary simplification for listed SMEs
Listed SMEs remain obliged to report under the CSRD framework, but Omnibus II introduces flexibility measures designed specifically for them:
- a simplified ESRS standard for SMEs, with fewer mandatory indicators,
- extended transitional periods,
- fewer quantitative requirements in the first reporting years,
- the possibility of deferring the obligation until 2030 with justification.
This simplification aims to prevent SMEs from being overwhelmed by methodological complexity, especially as regards the calculation of Scope 3 emissions or the collection of supply chain data.
Reinforcement and flexibility in the double materiality principle
The double materiality principle —which requires analysing both how sustainability affects the company and the company’s impact on the environment and society— remains a pillar of the CSRD system.
The Omnibus Agreement does not lower this requirement, but it introduces:
- greater clarity on how to document the process,
- flexibility to exclude non-material topics if properly justified,
- guidance so that companies can carry out the analysis without needing very costly external studies,
- the possibility of using the indicators more qualitatively in the early years.
Adjustments to the CSRD implementation timetable
The Omnibus package confirms and details the application timetable:
For large companies already covered by the NFRD and those first brought within the CSRD scope, it applied in the 2024 and 2025 financial years respectively.
- 2026 financial year: medium-sized listed companies.
- 2027 financial year: listed SMEs, with the possibility of deferral until 2030.
This phased roll-out seeks to ensure an orderly transition and to absorb the complexity of the new obligations for collecting, verifying and digitalising information.
Overall impact for companies not directly obliged
Although many organisations are not directly obliged, the effects of the Omnibus package are clear for the whole business fabric:
- more ESG information requests from large customers,
- new documentary requirements for supplier approval,
- more pressure to demonstrate due diligence in the value chain,
- growing demand for traceability and internal controls.
Together, the CSRD and the CS3D turn corporate sustainability from a reporting exercise into a central element of governance and risk management.
Conclusion
The Omnibus II Agreement represents a balance between ambition and practicality, since it maintains the strategic direction of the European Green Deal but introduces flexibility so that companies can adapt realistically. The combination of changes to the CSRD, the CS3D and the ESRS shapes a framework that strengthens transparency and due diligence while reducing the immediate pressure on many organisations.
For companies, 2026 is the year to consolidate processes, review materiality, prepare data systems and integrate sustainability as a key part of their competitiveness. At auma auma we support you in this process, strengthening practices and services aligned with the new European regulations.