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Home > Environmental, Social and Corporate Governance (ESG) > European Parliament Takes Next Step to Reduce Scope of CSRD

European Parliament Takes Next Step to Reduce Scope of CSRD

By John Verwey, Anna Maleva-Otto, Rachel Lowe, Sulaiman Malik & Michael Singh on October 9, 2025

On 8 October 2025, the European Parliament’s Socialists and Democrats (S&D) group ultimately accepted the European People’s Party (EPP)’s position on the Omnibus Directive, which revises the scope of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

Trilogue Negotiations

The next step is for the amended scope of the CSRD and CSDDD to proceed to trilogue negotiations between the European Commission, the Council of the European Union, and the European Parliament. Some convergence between their negotiating positions has already emerged.

All three institutions now agree that companies with fewer than 1,000 employees should be exempt from the CSRD. However, the financial threshold remains contested: the Commission has proposed a €50 million turnover threshold, while both the Council and Parliament support a significantly higher €450 million threshold.

With respect to the CSDDD, a consensus has formed around a 5,000-employee and €1.5 billion turnover threshold. This dramatically narrows the directive’s scope, excluding the majority of companies, and also eliminates any harmonized civil liability regime — a position now shared by all three EU institutions.

What’s Next

The European Parliament’s Committee on Legal Affairs (JURI) will hold its vote on 13 October, with a plenary vote expected the following week to formalize the Parliament’s position. The final trilogue negotiations, scheduled for November and December, will ultimately determine the final legal text of the directive.

For further information please contact ukreg@proskauer.com.  

Posted in Environmental, Social and Corporate Governance (ESG), UK/EU Financial Regulation
Tags: Corporate Sustainability Reporting Directive, Financial Regulation
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Photo of John Verwey John Verwey

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge…

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge fund managers as well as institutional managers and advisers, on all aspects of the UK and EU regulatory regimes.

Another key area of focus is advising clients in the financial services sector on mergers and acquisitions, re-organisations and associated regulatory approvals.

John represents a variety of clients that range from small start-up fund managers to established global fund advisers and managers. In The Legal 500, John is noted as “an all-rounder who gets into the details and manages client expectations on navigating tricky regulatory requirements”.

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Photo of Anna Maleva-Otto Anna Maleva-Otto

Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in…

Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in the UK, as well as trading on UK and EU markets.

Anna also often assists clients with the design of their compliance policies and procedures, internal investigations and staff training. She frequently participates in industry working groups in connection with new and emerging regulatory initiatives and has advised asset managers on several key pieces of recent EU legislation, including General Data Protection Regulation (GDPR), Short Selling Regulation, Alternative Investment Fund Managers Directive (AIFMD), the second Markets in Financial Instruments Directive (MiFID II), Market Abuse Regulation (MAR), the Securities Financing Transactions Regulation (SFTR), European Market Infrastructure Regulation (EMIR) and Securitization Regulation.

Anna has been named among the world’s 50 Leading Women in Hedge Funds by The Hedge Fund Journal and frequently speaks and writes on topics related to her areas of experience. She has previously co-authored the UK chapter in the Chambers Alternative Funds Guide – a guide examining key industry trends and regulatory and tax matters impacting funds, managers and investors.

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Photo of Rachel Lowe Rachel Lowe

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on…

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation. Rachel has also supported with EU MiFID and AIFMD sustainability updates for clients, including from a governance and organizational perspective, as well as providing drafting and training support. She also advises on the Corporate Sustainability Reporting Directive (CSRD), including analysis of its applicability for large international group structures.

From a UK perspective, Rachel supports clients with the TCFD-related requirements in the Financial Conduct Authority’s ESG Sourcebook and is increasingly engaged on the UK’s Sustainability Disclosure Requirements (SDR).

More broadly, Rachel has worked with litigation colleagues to assist clients with understanding and mitigating greenwashing-related legal and regulatory risk.

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Photo of Sulaiman Malik Sulaiman Malik

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers…

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers, as well as banks, FinTechs, broker-dealers and governments.

Prior to joining Proskauer, Sulaiman trained at Simmons & Simmons in London, where he was seconded to Brevan Howard. He has also spent time at the UK’s Ministry of Justice and as an adviser to the Mayor of Brisbane, in Australia.

Sulaiman is a passionate advocate for diversity and inclusion. He previously worked at Rare, a market-leading diversity consultancy, and provides pro bono legal advice to a range of community and civil rights organizations.

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Photo of Michael Singh Michael Singh

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms…

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms, investment managers, FinTech companies and wealth management businesses.

He is dual-qualified as a German lawyer (“Rechtsanwalt”) and Solicitor of England and Wales and previously was in-house counsel at Deutsche Bank.

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