Publication Type

Working Paper

Version

publishedVersion

Publication Date

11-2025

Abstract

This paper presents calculations related to the CSRD scope criteria which are modified through the Omnibus I Simplification Package. We show how many companies would be in scope of CSRD when considering the criteria suggested by (a) the Commission’s Omnibus proposal, (b) the position adopted by the Council of the EU, and (c) the European Peoples Party (EPP) proposal in the European Parliament. For each of these three “cases” we show the impact of lowering or increasing the employee-related threshold. 1.    Our calculations demonstrate that the number of in-scope companies varies significantly when modifying the employee threshold. We conclude from these calculations that increasing the threshold from 250 to 500 employees already has a significant impact in terms of exempting companies, as it would exempt around 17,400 EU companies under the Commissions’ proposal (with full subsidiary reporting). 2.    Our analysis also shows how the CSRD scope reduction affects different sectors in uneven ways. We find that some sectors critical to the green transition, such as real estate and agriculture, will see a significant drop in the number of companies required to report. In contrast, sectors that are less central to achieving green policy objectives, like healthcare provision and social work, will retain more companies within the reporting scope. This raises concerns about whether the Omnibus Package might weaken the availability of key information needed to guide the green transition and meet the goals of the EU Green Deal.3.   Considering the need to find a balance between lowering the cost burden and retaining impactful sustainability reporting, we make two proposals for a two-tiered reporting system in which companies with more than 500 employees report but without limits assurance. Both scenarios bring an additional 6,800 more companies into scope of the CSRD. While Scenario A would only add €326 million compliance costs per year, Scenario B would even lead to additional estimated compliance costs savings of about €437 million (all compared to the Commission’s proposal and including one-off costs).

Keywords

Sustainability Reporting, CSRD, Omnibus, Regulation

Discipline

Accounting | Public Policy

Research Areas

Integrative Research Areas

First Page

1

Last Page

17

Identifier

10.2139/ssrn.5350977

Publisher

SSRN

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