FERMA’s Policy Note: Final comparison table Omnibus I negotiations

FERMA welcomes the adoption by the Council of the Sustainability Omnibus package amending the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).  

FERMA has published a new policy note, “Final comparison table – Omnibus I negotiations”. This document provides a detailed overview of the final agreed text and assesses how FERMA’s advocacy priorities have been reflected. It is a follow-up to FERMA’s previously published policy note of 24 November 2025, which analysed the earlier stages of the negotiations. 

Overall, the final compromise text largely reflects the concerns raised by the European risk management community, in particular in the following areas:

  • Simplified ESRS while preserving double materiality 

The European Sustainability Reporting Standards (ESRS) will be simplified and streamlined, reducing unnecessary data points and improving clarity, while preserving the principle of double materiality. This ensures that reporting remains focused on what is truly material, in line with sound risk management practices. 

  • A more risk-based and proportionate due diligence framework 

The revised CSDDD strengthens the risk-based nature of due diligence. Companies will be able to prioritise areas where adverse impacts are most likely and most severe, relying on reasonably available information and applying proportionality. This approach allows organisations to allocate resources effectively while maintaining robust sustainability risk management. 

  • More time and clearer guidance for companies 

The extended implementation timeline and the European Commission’s commitment to issue practical guidance ahead of the application of the rules are also welcome. Clear guidance and sufficient preparation time will be essential to ensure consistent and effective implementation across the EU. 

FERMA stands ready to engage with EU institutions, Member States and stakeholders to support the smooth implementation of the Sustainability Omnibus and to continue contributing its expertise to these crucial discussions. 

Laurent Nihoul, FERMA CEO commented: “We welcome that the final text of the Sustainability Omnibus reflects most of FERMA’s key concerns. Simplifying the ESRS while keeping double materiality, strengthening a more risk-based and proportionate approach to due diligence, and giving companies more time and clearer guidance are important steps. When designed well, sustainability reporting and due diligence are not just compliance exercises, they are practical risk management tools that help companies stay prepared, resilient and competitive over the long term”.

 

Read the policy note here

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