Omnibus I: ESRS Quick Fix

The European Union (EU) is carrying out a thorough review of its sustainability regulations to try to simplify reporting and due diligence requirements through the Omnibus I package. For more information, see our Post | The EU Competitiveness Compass and the first omnibus proposals.

Given the magnitude of the Omnibus I reform, in April 2025, the European Commission (EC) approved the Stop-the-Clock Directive (2025/794/EU) that postponed by two years the reporting obligations under the Corporate Sustainability Reporting Directive (2022/2464/EU) (the CSRD) for wave two and wave three companies. This directive did not postpone the obligations for wave one companies that, in 2025, began reporting under the CSRD for the 2024 tax year. For more details, see our Post | Approval of "Stop-the-Clock" Directive: impact on business.

ESRS Quick Fix objectives and key measures

On July 11, 2025, the EC adopted a Delegated Regulation (the "ESRS Quick Fix") that gives flexibility to wave one companies regarding reporting obligations. This allows for a more gradual application of the first batch of European Sustainability Reporting Standards (ESRS) approved by Delegated Regulation 2023/2772/EU.

• Postponing additional reporting requirements
  
  Wave one companies will not be required to disclose additional information on the anticipated financial effects of certain sustainability-related risks for the 2025 and 2026 tax years. Companies could already omit this information when reporting on the 2024 tax year.
  
  
• Extending phased-in ESRS requirements
  
  All wave one companies will be able to omit the following requirements during the 2025 and 2026 tax years: ESRS E4 (biodiversity and ecosystems); ESRS S2 (workers in the value chain); ESRS S3 (affected communities); and ESRS S4 (consumers and end-users). Previously, this option was only available for companies with up to 750 employees.
  
  Additionally, companies that have up to 750 employees will also be able to omit the ESRS S1 (own workforce) requirements.

• Safeguard provision
  
  All companies that avail of this temporary exemption—including those with over 750 employees—must still report summarized information if they consider the matter to be relevant.

Access a table summarizing the modifications by company type here.

The ESRS Quick Fix will enter into force on the third day after its publication in the Official Journal of the EU and will apply to business years starting on or after January 1, 2025.

In parallel to this, the EC and the European Financial Reporting Advisory Group are working on a proposal to simplify the ESRS, and we will keep you informed of any developments.

For more information, please contact our Knowledge and Innovation Area specialists.