On February 26, 2025, the European Commission presented the so-called “Omnibus Package”. The aim of this initiative is to simplify existing regulations and directives in the areas of sustainability reporting, corporate due diligence and sustainable financial reporting. While the overarching objectives of the Green Deal are retained, bureaucratic hurdles are to be removed and the administrative burden reduced, particularly for small and medium-sized enterprises (SMEs).
A central component of the Omnibus Package concerns the Corporate Sustainability Reporting Directive (CSRD). Only companies with at least 1,000 employees and either a net turnover of more than 50 million euros or a balance sheet total of more than 25 million euros will be required to report. On top, the start of the reporting requirement will be delayed for 2 years (i.e. 2027 instead of 2025). This represents a considerable relief for many companies, as only around 20% of businesses will still be subject to CSRD reporting obligations. At the same time, the obligation to obtain sustainability data from suppliers not subject to CSRD will no longer apply, which will further reduce the burden. In addition, the sector-specific reporting standards in the European Sustainability Reporting Standards (ESRS) will be removed.
In addition to the CSRD, the Omnibus Package also affects the Corporate Sustainability Due Diligence Directive (CSDDD). The introduction of due diligence obligations for companies will be postponed by one year, i.e. to 2028. In addition, the proposed adjustments to the Supply Chain Directive also introduce further substantive relaxations. The definition of the value chain will be in general limited to direct business partners and previously mandatory contract terminations for non-compliance will no longer be required, with temporary suspensions now deemed sufficient. Sustainability reporting (CSRD) is now more closely integrated with supply chain due diligence requirements. The reporting obligations for smaller suppliers with fewer than 500 employees will be limited to the standards set by the voluntary sustainability reporting framework. This will result in simplifications for SMEs compared to the previous regulation. Furthermore, civil liability will be governed by the member states’ domestic law.
Another key point of the Omnibus Package is the adaptation of the EU Taxonomy Regulation, which serves as a classification system for sustainable economic activities. The reform aims at making things easier for companies by introducing a materiality concept for reporting obligations. In the future, companies would only have to report on taxonomy-compliant activities if they exceed certain thresholds.
The Omnibus Package simplifies the CO2 Border Adjustment Mechanism (CBAM) by introducing a 50-tonne annual threshold, exempting 90% of importers, mainly SMEs, while still covering 99% of emissions.
It is important to note that the Omnibus Package is still in the legislative process and must be approved by both the European Parliament and the Council before it can enter into force. In early April 2025, the European Parliament proposed a provisional timeline for negotiating the substantive contents of the CSRD and CSDDD amendments. The Legal Affairs Committee (JURI) aims to present a draft report by late June, with a deadline for submitting amendments set for June 27, 2025. Committee and plenary votes are expected to take place in October 2025. However, since the Council of the EU has not yet concluded its internal discussions, the final adoption of the changes could be delayed until late 2025 or beyond. Given the potential for political debate and further adjustments, companies should closely monitor developments and prepare for different regulatory outcomes.
Overview of regulations across the CEE region:
Austria
Czech Republic
Hungary
Slovakia
Poland
Austria
In Austria, the Omnibus Package will have a particular impact on sustainability reporting and the due diligence obligations of companies.
A hot topic is definitely the national implementation of the CSRD through the Sustainability Reporting Act (NaBeG). EU Directive 2014/95/EU, known as the Non-Financial Reporting Directive (NFRD), had been transposed into Austrian law by the Sustainability and Diversity Improvement Act (NaDiVeG) and applicable to certain companies since many years. While the CSRD has been in force since January 2023, the NaBeG is still at an early stage in Austria and was only published as a ministerial draft on January 13, 2025. The review period for this draft ended on February 10, 2025. The comments received are currently being reviewed before the draft was supposed to be submitted to the Austrian National Council for decision. This means that Austria has not met the implementation deadline of July 6, 2024, for the CSRD, leading already to legal uncertainty for Austrian companies. As a result, the European Commission had initiated infringement proceedings against Austria.
The Omnibus Package would obviously ease some of the originally strict requirements of the CSRD, NaBeG respectively. NaBeG would have implemented the thresholds and timings pursuant to the CSRD which would now have to be raised: Companies are only required to report once they have 1,000 employees and either 50 million euros in net sales or 25 million euros in total assets. This means, that a large proportion of Austrian companies are exempt from the reporting obligation, which reduces the administrative burden. In addition, the obligation to obtain sustainability data from suppliers (foreseen by CSRD and implemented pursuant to NaBeG) not subject to CSRD is eliminated, which further reduces the reporting burden.
Now, many parts of NaBeG will probably be overtaken by the Omnibus Package before it even enters into force. In particular, the new thresholds of the Omnibus Package could mean that some provisions of NaBeG will have to be renegotiated or adapted in order to comply with the new EU requirements. Companies should therefore not only keep an eye on national legislation, but also be prepared for possible subsequent amendments to the NaBeG.
Austrian companies that have already started producing sustainability reports, particularly those that, under the original CSRD timeline, were required to report in 2025 for the financial year 2024, may now face the question of whether they should continue this process. The current uncertainties could mean that the resources and costs already invested do not bring the expected benefits.
Beyond sustainability reporting, Austrian companies will also be affected by adjustments to the Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Taxonomy Regulation.
The CSDDD came into force on July 25, 2024, and member states have until July 26, 2026, to implement the directive into national law, with the provisions applying to companies from July 26, 2027. Austria has not yet submitted a draft for implementing the directive, so the immediate impact is currently limited. As mentioned above, the Omnibus Package will also bring changes in Austria by postponing due diligence obligations under CSDDD to 2028 and limiting them to direct suppliers, reducing compliance costs and easing implementation.
Austrian businesses subject to the EU Taxonomy, which as a regulation applies directly without the need for any national implementing legislation, would also benefit from the changes. The regulation primarily affects large and publicly listed companies, which were previously required to comprehensively report on their taxonomy-compliant activities. With the introduction of a materiality threshold, companies now only need to report if their sustainable activities exceed a certain limit. While this reduces bureaucracy and simplifies reporting, it also creates uncertainty, as it remains unclear whether companies that have already established reporting structures will now cease reporting entirely or continue voluntarily to maintain transparency and trust among investors and stakeholders.
Czech Republic
The Omnibus Package would bring similar effects also on the national regulations in the Czech Republic, in particular with respect to the sustainability reporting obligations.
So far, the sustainability reporting obligations under the CSRD have been incorporated into the Czech law via the Consolidation Package Act of 2023 (Act No. 349/2023 Coll.) which amended the Accounting Act. Pursuant to Section 32f et seq. of the Accounting Act, the sustainability report is a part of a company’s annual report which shall be filed with the commercial register. Currently, the obligation to produce a sustainability report is limited to entities falling under NFRD (public-interest entities), i.e. stock-listed companies with over 500 employees, banks, insurance companies etc.
However, the CSRD presently requires the sustainability reporting duty to be expanded to large undertakings (over 250 employees, 40 million euros net turnover and/or 20 million euros balance sheet) as of financial year 2025, i.e. a sustainability report by large undertakings is to be produced in 2026 for the financial year 2025. To reflect this so-called 2nd phase of the CSRD, the Ministry of Finance submitted a proposal for a new amendment to the Accounting Act in April 2024. The proposal is currently pending in the legislative process before the Chamber of Deputies within the Parliament of the Czech Republic. The amended Accounting Act would expand the duty to produce the sustainability report to large undertakings under Czech law. It is certainly recommended to continue monitoring the legislative developments and see how the Czech legislator would react if the Omnibus Package entered into effect before the adoption of the envisaged new amendment to the Accounting Act.
While a reduced reporting burden would be generally welcomed by Czech companies, many large companies have already committed resources and commenced their work on sustainability reports (and other non-financial reporting under the EU Taxonomy Regulation). This concerns e.g. the collection of data underlying the sustainability reports themselves which, in many cases, need to be collected throughout the year. In this context, it is possible that some companies could continue the sustainability reporting voluntarily notwithstanding the changes in the sustainability reporting to be introduced by the Omnibus Package.
As regards the corporate sustainability due diligence, the CSDDD has not been transposed into the Czech national law yet. In 2023, the government contemplated about transposing the CSDDD via amendments to the Civil Code and Business Corporations Act. However, in December 2024, the government tasked the Ministry of Justice to draft and propose a brand-new law, the so-called Act on Corporate Sustainability Due Diligence. The timeline set for introducing the draft law was originally set to October 2025. However, if the Omnibus Package is adopted at the EU level, the government might de-prioritize this task and defer the preparatory works on the draft law, taking into the account the due diligence obligations being postponed to 2028.
Hungary
Hungary has been proactive in transposing EU ESG directives into national law. The Corporate Sustainability Reporting Directive (CSRD) has been implemented through amendments to the Hungarian Accounting Act. These amendments adopted the CSRD's phased entry into force, company size limits, and the definition of the first reporting year with minimal changes, effective from January 1, 2024. Additionally, the new ESG Act, also effective from the same date, regulates the assessment and management of corporate environmental and social responsibility risks. The due diligence obligations under the ESG Act are substantially aligned with those in the Corporate Sustainability Due Diligence Directive (CSDDD), suggesting that the CSDDD’s implementation will likely be integrated into this ESG Act.
Given this framework, the EU “Omnibus Package” will likely significantly impact the sustainability reporting and due diligence obligations of Hungarian companies. The Ministry for National Economy has already initiated a local “Omnibus Package” by developing amendment proposals to the ESG Act. This action was prompted by the large number of Hungarian companies affected by the ESG Act — a scope similar to those under the Accounting Act’s sustainability reporting obligation — and the significant administrative burden it creates. The Hungarian Chamber of Commerce has requested a considerable relaxation of these rules from the Ministry.
One of the primary proposed changes is to grant large companies an additional two years to prepare their first certified ESG report, pushing the publication date to 2028. Furthermore, domestic micro, small, and medium-sized enterprises may be completely exempt from all ESG data reporting obligations until mid-2027. Even after this period, they would only have the option to complete a significantly shortened questionnaire. Additional proposals aim to ease the obligations of companies, such as removing the clause that requires a company to terminate business relationships with direct suppliers if their activities pose an increased risk of adverse effects.
The Ministry concluded the social consultation of these amendment proposals at the end of March 2025 to incorporate feedback from affected businesses and professional organizations. Consequently, the bill is expected to be passed by the Hungarian Parliament soon.
It appears that Hungarian companies must first monitor the rapidly evolving local ESG regulations, which align with the basic principles of the Omnibus Package. The subsequent easing of the ESG Act's provisions will likely lead to numerous interpretational challenges, requiring careful attention from affected businesses. However, the experiences gained here could be valuable when implementing the outcome of the EU Omnibus Package.
Slovakia
The EU "Omnibus Package" introduces significant changes to sustainability reporting and corporate due diligence obligations. These adjustments are also expected to have a notable impact on Slovak businesses and regulatory developments.
Slovakia transposed the previous EU Non-Financial Reporting Directive (NFRD) into its national law through the Act on Accounting (Zákon o účtovníctve). Under this regulation, large public-interest entities, such as banks, insurance companies, and listed firms with over 500 employees, have been required to disclose non-financial information. The implementation of the EU Corporate Sustainability Reporting Directive (CSRD) was set to expand these obligations significantly, requiring large companies that meet at least 2 of the 3 criteria, i.e. over 250 employees, a turnover exceeding €40 million, or assets over €20 million to comply with new sustainability reporting rules from the financial year 2025. Sustainability report by large undertakings is to be produced in 2026 for the financial year 2025. To align with the CSRD, at the end of April 2024, the Parliament of the Slovak Republic approved the expected amendment to the Accounting Act. This amendment implements the CSRD into local law, extending its obligations to large enterprises, effective June 1, 2024. Additionally, the amendment addresses the impact of recent inflation and incorporates another EU directive adjusting company size criteria, thereby reducing the administrative burden for certain businesses by exempting them from preparing a sustainability report.
Omnibus Package introduces key relaxations to these reporting requirements, which could reshape Slovakia's approach to sustainability reporting. Although reducing reporting burden would generally benefit Slovak businesses, many large companies have already invested resources and initiated the process of preparing sustainability reports, along with other non-financial disclosures required by the EU Taxonomy Regulation. A key aspect of this process is data collection, which often needs to be conducted continuously throughout the year. As a result, despite the forthcoming changes under the Omnibus Package, some companies may still opt to continue sustainability reporting on a voluntary basis.
Beyond sustainability reporting, Slovak companies will also be affected by adjustments to the Corporate Sustainability Due Diligence Directive (CSDDD). The Omnibus Package introduces further changes, delaying due diligence obligations under the CSDDD until 2028 and restricting them to direct suppliers, thereby lowering compliance costs and simplifying implementation.
The CSDDD has not yet been transposed into Slovak national law, and no draft laws have been presented so far. It can therefore be assumed that if the Omnibus Package will be adopted, the government will propose a draft of act that reflects the Omnibus Package, taking into account that due diligence obligations have been postponed until 2028.
Poland
The introduction of the Omnibus Package would similarly result in the changes in the Polish law, especially in respect to reporting and taxonomy.
The CSRD has been implemented into the Polish law via the act of 6 December 2024 amending the accounting act, the act on statutory auditors, audit firms and public supervision and certain other acts. The amendment will come into force throughout 2025. The vast changes to several legal acts were significant. Most significantly, auditors that attest sustainability reporting, will be required to obtain additional qualifications in this respect. The information on the ESG-competent auditors will be kept with the National Council of Statutory Auditors (KRBR) in the register of auditors. Furthermore, a timeline for introduction of ESG reporting within businesses was set up. The earliest requirements of ESG reporting were set for a group of companies considered to be large public interest entities (PIEs), which include listed companies, banks, insurance companies, as well as PIEs that lead largest capital groups. Those entities are required to start ESG reporting as early as for 2024. In 2026, the ESG reporting requirement will reach also other large entities as well as their capital groups. Small and medium-sized enterprises (SMEs) are next in line to adapt to ESG reporting, albeit with some simplification and extended deadlines. It is estimated that approximately 100.000 companies in the value chain of the above entities will be affected by the reporting. They will be “asked” to provide applicable ESG-related data.
The Omnibus Package will not impact the biggest PIEs that employ over 1.000 people, have a balance sheet total in excess of EUR 25 million or generate net revenue in excess of EUR 50 million. They will be obliged to continue with the ESG reporting, as required by European Sustainability Reporting Standards (ESRS). For other PIEs, SMEs and other entities, which constitute around 80% of businesses, the deadlines for introduction of the ESG reporting will be postponed or considered voluntary. It is also considered that the sheer volume of data required within the ESG reporting will be cut down in number. It is expected that changes would reduce the number of companies required to conduct the ESG reporting (from around 50,000 down to 10,000).
The Polish legislator has not yet introduced draft legislature transporting the planned Omnibus Package into Polish law. It is expected that such changes will only be conducted after the finale implementation of the Omnibus Package.
Go back to the overview.
