On Thursday 13 November 2025, the European Parliament (the "Parliament") concluded months of fractious negotiations and voted to agree a final Negotiating Position on the Omnibus I package – consisting of the Corporate Sustainability Reporting Directive ("CSRD"), the Corporate Sustainability Due Diligence Directive ("CSDDD"), and the EU Taxonomy Regulation - part of the European Commission's initiative to streamline certain EU (sustainability) laws.

Background

The vote saw the EPP, the Parliament's main centre-right party, rely on support from a right-wing coalition in the Parliament to vote through the Negotiating Position (the text of which can be found here). A previous compromise text (the "JURI compromise") supported by a coalition of the Parliament's centrist parties had been rejected at a plenary vote on 22 October. We covered this previous compromise here.

We have also previously covered developments relating to the EU Omnibus I Package, including the EU Commission's proposal for the Omnibus I package, and the Council of the EU's negotiating position on the Commission's proposal.

Here, we briefly explore the key points of interest in the Negotiating Position, particularly where it departs from the JURI compromise.

CSDDD – sustainability due diligence

Much of the Negotiating Position for the CSDDD remains aligned with the JURI compromise, particularly in terms of (i) scope, (ii) transposition deadlines, (iii) removal of a review clause on the inclusion of financial undertakings, and (iv) the removal of an EU-wide civil liability regime.  There are, however, some significant points of difference, which are also likely to feature prominently in trilogue negotiations:

Climate transition plan

In the same day that the Parliament adopted a proposal to set a binding emissions reduction target of 90 percent by 2040 (with certain flexibilities), it also voted to remove from the CSDDD the requirement to "adopt and put into effect a transition plan for climate change mitigation" aligned with the 1.5°C temperature goal set by the Paris Agreement, and the EU's target of achieving climate neutrality by 2050.

The Council position, by contrast to the Negotiating Position, includes a requirement for companies to adopt a climate transition plan with "implementing actions" that contributes to the Paris Agreement (but removes mention of the 1.5°C temperature goal).  

Due diligence obligations

The Negotiating Position cleaves to the JURI compromise drafting on due diligence obligations in many respects. However, in the context of actual or potential adverse impacts of a business partner which could not be prevented or adequately mitigated, the Negotiating Position removes the obligation ("shall") for companies to refrain from entering into new or extending existing relations with such a business partner, in favour of the optional "can".

Financial penalties

As with the JURI compromise, the Negotiating Position is that Member State supervisory authorities would be assisted by guidance prepared by the Commission, in collaboration with Member States, as to the appropriate level of penalties for infringements of provisions of national law adopted pursuant to the CSDDD, taking into account the turnover of companies. The Negotiating Position however removes specific percentage limits associated with the net worldwide turnover of a company, which had been included in the JURI compromise.

CSRD – sustainability reporting

While, again, much of the Negotiating Position for the CSRD remains aligned with the JURI compromise, particularly on (i) timing, and (ii) reporting obligations, the Negotiating Position would further reduce the scope of application of the CSRD. '

While the threshold requirement for a net turnover of EUR 450 million during the financial year remains aligned with the JURI compromise and Council negotiating position, the Negotiating Position would also require companies to have over 1,750 employees (rather than over 1,000) to be in scope of the CSRD.

EU Taxonomy Regulation

In common with the Council's position, the Negotiating Position does not pick up the Commission's proposal to make reporting under the EU Taxonomy Regulation voluntary for certain companies.

Next steps

The adoption of the Parliament's Negotiating Position opens the door to trilogue negotiations, which are set to commence on 18 November, facilitated by the Commission. The aim remains to finalise the legislation by the end of 2025.

Outlook

Given that the Parliament and Council are far apart on key elements of the Omnibus proposal, particularly in relation to obligations with respect to climate transition plans, the final shape of the Omnibus remains uncertain.