The EU officially agreed on a major recalibration of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) on December 16, 2025.
The goal is simplification but not elimination. While fewer companies will be in scope in the near term, expectations for data quality, governance, and value-chain visibility remain firmly intact.
Here’s what matters most.
EU Trilogue updates, at a glance
The revised EU Omnibus Package significantly narrows scope, delays timelines, and introduces more proportional, risk-based requirements, especially for value-chain due diligence.
At the same time, it preserves the core architecture of CSRD and CSDDD: ESRS-aligned reporting, double materiality, and investor-grade disclosures.
CSRD: Key changes
Who’s in scope now for CSRD post-trilogue discussions
CSRD now applies to large companies only:
- 1,000+ employees
- €450M+ net turnover
This reduces the number of mandatory reporters by an estimated 80%.
Non-EU companies are in scope if they:
- Generate €450M+ EU turnover, and
- Have an EU subsidiary or branch generating €200M+ turnover
Timing adjustments
- Wave 2 companies: first CSRD report in 2028 (FY 2027)
- Non-EU companies: first CSRD report in 2029 (FY 2028)
Many companies may be exempt for FY 2025–2026, depending on Member State implementation.
What doesn’t change
- Double materiality stays
- Reporting must still align with ESRS
- Limited assurance remains the standard (for now)
A simplified ESRS, expected in 2026, will require fewer datapoints and clearer materiality guidance.
CSDDD: A shift to risk-based due diligence
CSDDD has been streamlined even further, with a clear move toward proportionality.
Key updates to CSDDD post-trilogue discussions
- Scope raised to:
- 5,000+ employees and €1.5B global turnover (EU companies), or
- €1.5B EU turnover (non-EU companies).
- Implementation delayed:
- National transposition by July 2028.
- Company compliance required by July 2029 .
What’s new (and notable) for CSDDD
CSDDD is taking a fully risk-based approach to due diligence. Companies can prioritize the most severe and likely risks across the value chain, not just Tier 1 suppliers. This includes:
- SME protections: data requests must be genuinely necessary and proportionate
- Climate transition plans removed from CSDDD (but still disclosed under CSRD, where applicable)
Penalties capped at 3% of global turnover, and civil liability has been removed from CSDDD mandates.
What this means for Sustainability leaders
Even if your company is no longer immediately in scope, three realities remain:
Investors still expect CSRD-grade data
CSRD has become the de facto benchmark for decision-useful sustainability disclosures.
Value-chain pressure hasn’t disappeared
Large companies will still need high-quality supplier data — just collected more strategically.
The window to modernize is open
The delay creates time to fix fragmented systems, automate data collection, and operationalize materiality—before reporting becomes mandatory again.
What to do next for future CSRD and CSDDD preparedness
If CSRD or CSDDD is on your radar —even if timelines moved — now is the moment to:
✅ Reassess in-scope status under the new thresholds
✅ Refresh or run a double materiality assessment aligned to revised ESRS
✅ Map value-chain data gaps with a risk-based lens
✅ Centralize sustainability, climate, and ESG data in one system
✅ Prepare for audit-ready, limited-assurance reporting
How Pulsora can help
Pulsora supports enterprises across CSRD, CSDDD, ESRS, and global ESG requirements, from materiality and value-chain data collection to audit-ready reporting and investor-grade insights.
Whether you’re preparing now or future-proofing for what’s next, we help you build a sustainability data foundation that lasts.
Book a demo to see how Pulsora simplifies CSRD and CSDDD end to end.
