On 9 December 2025, negotiators from the European Parliament (EP), the Council of the European Union (the Council) and the European Commission reached a provisional political agreement on the final text of their “Omnibus” package amending the Corporate Sustainability Reporting Directive (CSRD).

Though the final text is not yet published, the publicly-available press-releases confirm a substantial narrowing of the CSRD’s scope, representing around five to 10 percent of the original number of entities that were captured:

  • For EU companies: 1,000 employees and at least €450 million net turnover.
  • For non-EU companies: At least €450 million net turnover in the EU. Any minimum net turnover thresholds for EU branches/subsidiaries were not announced and will need to be reviewed in the final text.
  • Exemptions/Transition: Financial holding undertakings are exempt; “wave one” companies that started reporting for FY2024 but fall out of scope will benefit from a transition exemption for FY2025–2026.

The change reflects a broader recalibration that the EU is seeking to simplify sustainability reporting obligations and reduce the compliance burden on companies, particularly for smaller firms.

What next?

The EP is expected to formally adopt the Directive at its plenary session on 15-18 December 2025. The Council must also formally adopt the text before publication in the Official Journal, after which the new thresholds and related amendments will enter into force.

What about the standards themselves?

The development on scope comes at the same time as progress on the content and form of sustainability reporting under the revised reporting standards.

On 3 December 2025, EFRAG submitted to the Commission its technical advice on draft simplified European Sustainability Reporting Standards (ESRS) as part of the Omnibus initiative.

These draft-simplified ESRS reduce the mandatory data points by 61 percent, streamline the materiality assessment, remove a range of voluntary disclosures and introduce greater flexibility and proportionality in reporting, including relaxed requirements for value-chain data collection and more emphasis on fair presentation and decision-usefulness of information.

For further information, please reach out to ukreg@proskauer.com

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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”.

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.

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.

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.

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.