EU digital omnibus: What changes for CSRD, CSDDD and Swiss companies

In EU legislative language, an Omnibus is not a new regulation.

It is a package of amendments that adjusts multiple existing laws at once.

The current Omnibus initiative — often referred to as the *Digital* or *Sustainability* Omnibus — is part of the European Commission’s competitiveness and better-regulation agenda, explicitly aimed at reducing administrative burden, especially for SMEs.

In practice, the Omnibus:

amends CSRD scope and reporting mechanics,

revises how ESRS standards are applied,

adjusts EU Taxonomy obligations,

and modifies timelines and elements of CSDDD implementation.

What it is not:

a repeal of sustainability regulation,

a signal that ESG scrutiny is going away,

or a guarantee that value-chain pressure will stop.

This distinction matters, because many companies are already mis-reading the signal.

The European Commission states that the Omnibus will remove around 80% of companies from the scope of mandatory CSRD reporting.

How? By introducing a much higher employee threshold (1,000+), combined with financial criteria.

For many companies originally expected to report under “Wave 2” or “Wave 3”, this is a real change.

However, two caveats are critical:

Scope is not the same as exposure

Being out of scope does not mean being out of the data chain.

Third-country logic still exists

CSRD was explicitly designed to apply to non-EU parents with significant EU activity.

For Swiss groups, the question is no longer *“Are we in CSRD?”*

It is *“Where does CSRD still reach us?”*

Under the Omnibus, the Commission has clearly signalled that:

ESRS will be revised and simplified,

sector-specific standards will be dropped,

and assurance will remain at limited assurance, not “reasonable assurance”.

This is often interpreted as a downgrade.

In reality, it is a shift in enforcement logic:

fewer prescriptive templates,

more management judgement,

more reliance on governance, controls, and traceability.

In audit terms, this increases:

documentation risk,

consistency risk,

and board oversight risk.

Less structure does not mean less scrutiny — it means fewer excuses.

One of the most important (and misunderstood) elements of the Omnibus is the introduction of a voluntary SME standard (VSME).

The Commission’s stated goal is to:

prevent large companies and banks from pushing unlimited CSRD data requests down the value chain,

and create a *cap* on what can reasonably be requested from smaller suppliers.

For Swiss SMEs supplying EU corporates, this matters.

But the shield has limits:

it does not stop customer questionnaires,

it does not eliminate due-diligence expectations,

and it does not protect against reputational or contractual pressure.

It changes the *rules of engagement* — not the existence of engagement.

Under the Omnibus, mandatory EU Taxonomy reporting will be limited to the largest companies.

However:

financial institutions still use taxonomy logic in credit decisions,

investors still reference taxonomy alignment,

and customers increasingly expect “taxonomy-like” explanations, even when not mandatory.

For Swiss exporters and industrial groups, taxonomy influence persists indirectly — through financing and procurement.

A separate Omnibus proposal delays certain CSRD (and CSDDD) application dates by up to two years, giving legislators time to finalise the new scope and standards.

This is not a grace period to do nothing.

It is a window to:

reassess scope properly,

redesign reporting architecture,

and avoid sunk-cost compliance programmes that no longer fit.

The Corporate Sustainability Due Diligence Directive (CSDDD) entered into force in July 2024.

That means:

the legal duty exists,

expectations around supply-chain due diligence are real,

and enforcement will follow, even if timelines shift.

The Omnibus includes amendments and timing adjustments, but it does not remove the core concept:

companies must identify, prevent, mitigate and address adverse impacts in their operations and value chains.

Based on Commission materials, the Omnibus:

aligns timelines with CSRD changes,

simplifies certain procedural elements,

and reduces immediate burden for smaller companies.

What it does not do:

eliminate supply-chain scrutiny,

remove civil liability discussions,

or stop customers and regulators from expecting due-diligence evidence.

For Swiss companies, CSDDD is often felt indirectly:

through customer codes of conduct,

supplier audits,

and contractual ESG clauses.

This will continue.

A Swiss parent can still be pulled into CSRD if it:

generates significant turnover in the EU (notably €150m+),

and has an EU subsidiary or branch presence.

This is not theoretical.

Many Swiss industrial, pharma, and technology groups fall into this category.

The Omnibus does not remove this logic — it refines thresholds.

Even when formally out of scope, Swiss companies face:

customer data requests,

bank ESG questionnaires,

and audit committee pressure for consistency.

The Omnibus may reduce *how much* data is requested.

It does not remove the expectation that you can answer coherently.

The most common misconception we see:

“If we’re out of scope, ESG reporting is no longer a board issue.”

In reality, Omnibus increases:

judgement calls,

cross-border interpretation,

and accountability for *why* something was or wasn’t reported.

That is squarely a board responsibility.

Do this deliberately — not informally.

Lane A: EU entities

Which EU subsidiaries remain in scope under revised thresholds?

Which drop out — and on what legal basis?

Lane B: Swiss parent

Do we meet the third-country CSRD criteria?

Are we exposed via consolidated reporting expectations?

Output:

A one-page board memo with three outcomes:

In scope

Likely in scope later

Out of scope but value-chain exposed

Assume you *will* be asked for ESG information — even if not legally required.

Prepare:

governance structure and accountability,

top material risks and impacts (not everything),

policies and controls that exist,

clear boundaries on what you do not provide.

This aligns with the Commission’s intent and protects you from uncontrolled data creep.

With simplified ESRS and limited assurance, success depends on:

data ownership,

change control,

evidence retention,

and traceability from source to statement.

Narrative ESG reporting without controls is now the highest-risk position.

For most Swiss firms, CSDDD compliance equals:

supplier mapping,

risk screening,

escalation procedures,

and board-level oversight cadence.

If you can demonstrate those, you are ahead — Omnibus or not.

The EU Digital Omnibus does not lower expectations.

It changes who must decide, what is material, and how defensible your judgement is.

For Swiss companies, the real risk is not over-compliance.

It is misinterpreting silence as safety.

If your organisation is asking:

“Do we still need to care about CSRD and CSDDD?”

You are already asking the wrong question.

The right question is:

“Where does regulatory judgement now sit, and are we prepared to defend it?”

That is where boards will be tested in 2025–2026.