Omnibus Regulation 2025: Using the Omnibus Effects as a Tailwind to Calculate CO2 Consistently Now

When the European Commission presented its major “Omnibus package” on 26 February 2025, many sustainability and finance departments breathed a sigh of relief: finally, less bureaucracy. But on closer inspection, it is an invitation to drive climate management and CO2 calculation forward in an even more targeted way.

1. What exactly is in the Omnibus Regulation?

The Commission combines several directives and regulations – from the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) to the EU Taxonomy and the Carbon Border Adjustment Mechanism (CBAM) – into a single relief package.
The core idea: cut reporting and audit obligations for companies by 25%, and for small and medium-sized enterprises (SMEs) even by 35%.

This includes three decisive levers:

• Higher thresholds: in future, only companies with more than 1,000 employees and either a balance sheet total above €25 million or turnover above €50 million will fall under the mandatory CSRD reporting obligations. This reduces the group of obliged companies by around 80%.
• “Stop-the-clock” postponement: for companies that would actually have to submit their first CSRD reports in 2026 or 2027 (the so-called “wave 2 and wave 3 companies”), the start is postponed by two years to 2028 and 2029 respectively.
• Simplified CBAM: a new threshold of 50 tonnes of imported goods per calendar year per supplier exempts the majority of small importing companies from the complex border adjustment obligations, without diluting the bulk of the emissions covered. According to the Commission, ≈ 90% of previously affected companies drop out of the system, while ≈ 99% of the emissions covered today remain regulated, as the large volumes lie with a few large companies.
• CSDDD softened: the due diligence obligation only applies from 26 July 2028 and only to EU companies with 1,000 or more employees/€50 million turnover (non-EU groups only from €450 million EU turnover). In addition, risk checks must primarily target direct suppliers; downstream tiers are only examined every five years or where there are concrete indications.

These structural changes – the Omnibus effects, in short – take effect as soon as Parliament and Council agree, which is expected by the end of 2025. Until then, companies should use the time gained strategically.

2. Why these Omnibus effects are an invitation to calculate CO2

Fewer formalities, more impact
What sounds like deregulation is in fact room to manoeuvre: instead of rigid reporting checklists, companies can align their climate strategies on their own terms. For SMEs, the fear of fines for formal errors disappears; they can calculate CO2 voluntarily and show customers and investors a credible climate position.

Budget shifts from paper to climate projects
The EU estimates that companies will save up to €40 billion a year with the Omnibus package. That is capital that can flow into energy efficiency, renewable energy or low-emission supply chains instead of auditor and consultant fees.

A technology window until 2028
The postponement creates a rare window of time to introduce digital carbon accounting platforms, build data pipelines and train employees. Those who seize this opportunity will start 2028 with a mature, automated system – not with hastily copied-together Excel spreadsheets.

Protection for small suppliers
Harmonising the CSRD and CSDDD thresholds prevents large corporations from outsourcing granular data collection to very small suppliers. This reduces pressure in the supply chain, but transparency is preserved – provided all players calculate their CO2e emissions and share the results in a structured way.

Predictable border costs thanks to the CBAM threshold
The 50-tonne exemption gives importers predictable costs and frees specialist traders and niche producers in particular from complex certificate processes – as long as they keep an eye on their emissions.

3. How to turn relief into climate impact

a) Strengthen your data culture
Start a gap analysis now: which emission sources are not covered, where is accurate information missing? A lean API layer to ERP systems or IoT sensors will soon replace tedious manual input. The more valid your data basis, the lower the audit effort for the “limited assurance” that the Omnibus Regulation explicitly retains.

b) Prioritise Scope 3
As the CBAM threshold excludes many direct import emissions, the lever for decarbonisation shifts to upstream and downstream processes. A complete Scope 3 footprint reveals hotspots where reductions are most effective, for example in transport, packaging or business travel.

c) Practise early for 2028
Even if the reporting obligation is postponed, customers, banks and rating agencies have long demanded traceable climate data. Companies that voluntarily calculate and publish CO2 now secure a lead in trust when the big reporting wave starts in 2028.

Conclusion: use your room for manoeuvre now

The Omnibus Regulation takes the pressure off excessive reporting obligations, but it does not release anyone from responsibility. Those who invest the freed-up resources wisely can set up reliable emission balances within the next three years, prioritise measures and communicate credibly. In short: the best response to the Omnibus effects is to calculate CO2 even more precisely today – and to convince with real climate facts tomorrow.