CSRD, CSDDD and EUDR: three European laws affecting your value chain

Update on European sustainability legislation: Omnibus, CSRD, CSDDD and EUDR

Developments surrounding European sustainability legislation are following in rapid succession. This week, the European Parliament decided not to advance the so-called Omnibus proposal to the next implementation phase. The vote was close: 309 in favour, 318 against and 34 abstentions. The division was broad, with both progressive and conservative parties voting against, albeit for different reasons.

The consequence is that the dossier proceeds to the plenary session of 11-13 November. In the lead-up to that session, negotiations will resume on the scope of the dilution of the CSRD (Corporate Sustainability Reporting Directive) and the CSDDD (Corporate Sustainability Due Diligence Directive).

What is at stake?

The discussion does not focus on the content of the reporting standards (ESRS) or the effective date, which remain intact, but on the target group thresholds: which companies precisely fall under the directive.

The current CSRD thresholds are:

• 250 employees,
• EUR 50 million in turnover,
• EUR 25 million in total assets (2-of-3 criterion).

The Omnibus proposal suggests raising this threshold to:

• 1,000 employees (mandatory),
• and EUR 50 million in turnover or EUR 25 million in total assets.

The final threshold, above or below 1,000 employees, will depend on the outcome of the upcoming negotiations. For non-listed but reporting-obligated enterprises, the first reporting year remains financial year 2027 for the time being.

Movement around the EUDR as well

In addition, the European Commission is preparing the introduction of the EUDR (European Deforestation Regulation). This legislation relates to the import and trade of, among others, timber, cattle, leather, soy, palm oil, cocoa, coffee and rubber.
The planned effective date is 30 December 2025 for medium-sized and large enterprises, with a transition period of six months for upstream parties. For small and micro enterprises, 30 December 2026 is envisaged.

What does this mean for organisations?

Although further political negotiations will follow, it is clear that sustainability reporting is becoming a structural part of business operations in Europe. The precise thresholds may still change, but preparation remains essential.

Kroll SR continues to monitor developments and will share relevant updates as soon as they become available.