Agreement On The CSRD/CS3D Omnibus Package: Key Changes And Implications

On December 9, 2025, the European Parliament and the Council concluded a deal in the trilogue negotiations on the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D) Omnibus Package. On December 16, a plenary vote in Parliament took place approving the text.

The result of the negotiations reduces the number of entities falling in scope of the CSRD by around 90% and those falling in scope of the CS3D by around 70%. It also reduces administrative burden for in-scope companies while at the same time increasing fragmentation risks across member states, particularly on liability and enforcement of the CS3D.

Multinationals with substantial EU operations should reassess group-level exposure, reporting architectures and assurance readiness in light of the new thresholds and interpretive ambiguities.