The European Commission has adopted the Omnibus Simplification Package to streamline sustainability reporting requirements under key EU directives, including the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CS3D), and the EU Taxonomy Regulation. These changes are expected to reduce reporting burdens for businesses, aligning regulatory frameworks with economic competitiveness while ensuring ESG compliance. 

The CSRD’s scope has narrowed significantly, now only applying to companies with more than 1,000 employees and either €50 million in net turnover or €25 million in balance sheet total. This adjustment removes up to 80% of previously covered entities from compliance, easing the burden on smaller firms. Additionally, the first reporting deadlines have been postponed from 2025 to 2027 to allow businesses more time to adapt. 

The EU Taxonomy Regulation has been adjusted to align with CSRD thresholds, applying only to firms generating over €450 million in revenue. For other companies, taxonomy reporting becomes voluntary. Additionally, firms whose taxonomy-eligible activities account for less than 10% of their business are now exempt from reporting. The number of required data points in taxonomy disclosures will also be cut by 70% to reduce complexity. 

The Corporate Sustainability Due Diligence Directive (CS3D) will now focus only on direct suppliers (tier 1) instead of the entire value chain, with due diligence reviews shifting from an annual to a five-year cycle. Enforcement has also been delayed by one year to July 2028, and financial penalties have been reduced. 

Luxembourg’s draft Bill No. 8370, which transposes CSRD into national law, may need revisions to reflect these changes, including raising the applicability threshold and delaying reporting deadlines. For investment funds, the reduction in ESG data availability could pose challenges, particularly for private equity and infrastructure funds that rely on company disclosures. Institutional investors may reassess fund attractiveness based on ESG data reliability, raising concerns about greenwashing. 

The Omnibus Simplification Package now awaits approval by the European Parliament and Council, with final implementation expected after formal adoption. 

情報源 

https://insightplus.bakermckenzie.com/bm/banking-finance_1/luxembourg-eu-omnibus-simplification-package-implications-for-luxembourg-entities-and-investment-funds 

https://cms.law/en/lux/publication/newsflash-omnibus-directive-what-are-the-implications-for-luxembourg-investment-fund-managers