Market Views, ESG | Wiersholm: The Omnibus Proposal – Simplified Rules for Sustainability Reporting

Summary

• As part of the EU Omnibus proposal, the implementation of the CSRD (Corporate Sustainability Reporting Directive) has been postponed by two years for companies that were supposed to report under the CSRD in 2026 and 2027 (waves 2 and 3).
• The postponement by two years does not apply to large public interest entities, including banks, credit institutions and insurance companies and listed companies (wave 1). These entities are still obliged to report under the CSRD for the financial year 2024, with a reporting deadline in July 2025.
• The Omnibus proposal does not abolish the CSRD. The directive will still apply to large companies; however, the European Commission has proposed to narrow the scope, so that only companies with more than 1,000 employees (with separate requirements relating to either turnover or balance sheet total) are included.
• If adopted, the Omnibus proposal will remove the reporting obligation for a number of companies that currently are subject to the CSRD. It is expected that the proposal will affect approximately 1,000 Norwegian companies.
• To date, the EU has only adopted the part of the Omnibus package concerning postponement of reporting requirements. Negotiations on the "main amendments" are scheduled for autumn 2025.

CSRD - Current Status

Status in the EU

In recent years, the EU regulatory landscape has become increasingly complex following the introduction of new reporting and due diligence requirements. Several member states and companies have expressed concern over the administrative burdens and costs associated with the implementation of new regulations, especially the Corporate Sustainability Reporting Directive (CSRD). In addition, several reports show that EU businesses are losing competitiveness to the US and China. Increased reporting requirements for businesses have been pointed out as one contributing factor to this.

To meet these challenges, the European Commission launched the first part of the announced "Omnibus package" on 26 February 2025. The purpose of the Omnibus proposal is to reduce regulatory requirements for companies in the EU and increase EU competitiveness. In particular, the European Commission aims to reduce reporting requirements for small and medium-sized companies, to ensure that these requirements are primarily targeted at the largest companies with the greatest impact on sustainability issues. The proposal entails significant amendments to the rules on sustainability reporting under the CSRD and the EU taxonomy, which will have consequences for, inter alia Norwegian real estate companies.

As part of the Omnibus package, the European Commission proposed to postpone the implementation of the CSRD by two years, to give time for the EU to discuss and agree on the other amendments. This proposal, known as the Stop-the-clock Directive, was quickly adopted and entered into force in the EU on 17 April 2025. This implies that the reporting requirements are now put on hold for companies that have not yet reported under the CSRD, i.e. companies included in waves 2 and 3[1], (which were due to report under the CSRD in 2026 and 2027). This part of the Omnibus package will not have any impact on companies included in wave 1, in which reporting obligations have already been introduced. These companies (including banks, credit institutions, insurance companies and listed companies) must still report under the CSRD for the financial year 2024, with a deadline on 31 July 2025.

[1] Wave 2: From the financial year 2025 with reporting in 2026: Other large companies that meet two of the following three criteria: (i) balance sheet ≥ NOK 290 million, (ii) sales revenue ≥ NOK 580 million, and (iii) ≥250 employees.

Wave 3: From the financial year 2026 with reporting in 2027: Inter alia listed small and medium-sized companies that meet two of the following criteria: (i) balance sheet total ≥ NOK 5 – 290 million, (ii) sales revenue NOK 10 – 580 million, and (ii) 10 – 250 employees.

CSRD simplification

The Omnibus proposal entails significant simplifications to the sustainability reporting requirements under the CSRD. The European Commission proposes, inter alia, to raise the threshold values required for a company to be subject to the CSRD. Furthermore, the distinction between listed and private companies is removed, so that the scope of the CSRD is only based on one size criteria. In addition, the proposal introduces a voluntary reporting standard for companies that are not required to report under the CSRD, as well as revised and simplified ESRS standards (European Sustainability Reporting Standards). The proposal also amends the requirement for auditor verification.

Below, we have provided a more detailed overview of the specific changes:

• Higher threshold: The European Commission proposes to raise the threshold for when a company is required to report under the CRSD, so that only companies with more than 1,000 employees are included (i.e. companies that have more than 1,000 employees and either a turnover above EUR 50 million or a balance sheet above EUR 25 million).
• Voluntary reporting standard: The proposal introduces a voluntary reporting standard for companies that are not subject to the CSRD but wish to submit sustainability reporting on a voluntary basis. This standard has been prepared by the advisory body EFRAG and is based on the current standard for small companies, VSME. The standard will also serve as an outer limit for what information reporting companies may request from their activity chain.
• Simplification of the ESRS standards: The European Commission proposes to revise the ESRS standards that companies are required to report in accordance with. The aim is to reduce the number of mandatory data points and provide clearer guidance, particularly on the use of the double materiality principle.
• Sector-specific standards: The EU has previously announced that work is in progress to develop sector-specific standards, which will apply in addition to the 12 general ESRS standards that have already been adopted. The European Commission is now proposing to remove the mandate to adopt these standards.

• The auditor verification requirement: Today, the CSRD requires that auditor verification is provided with "limited assurance". The European Commission proposes that this requirement remains the same, instead of imposing even stricter assurance requirements for auditor verifications.

Status in Norway

The CSRD has been implemented into Norwegian law through sections 2-3 and 2-4 of the Norwegian Accounting Act, which came into force on 1 November 2024. On 11 April 2025, the Ministry of Finance issued a consultation proposal regarding the implementation of the Stop-the-clock Directive into Norwegian law. As mentioned above, the proposal entails postponed reporting obligations for companies that have not yet reported under the CSRD, meaning that Norwegian companies will face the same application dates as companies in the EU. The deadline for submitting comments on the proposal was 23 May. It is expected that the proposal will be adopted shortly.

If the Omnibus proposal is adopted and implemented into Norwegian law, the reporting obligation will lapse for approximately 1,000 Norwegian companies that are currently subject to the CSRD. The Ministry of Finance has expressed that Norwegian companies should in principle be subject to the same requirements as companies in the EU. It is therefore likely that any amendments adopted by the EU will be implemented into Norwegian law. However, it is uncertain when the proposal will be adopted in the EU and what changes and adjustments the Council and the Parliament will make. For the time being, Norwegian companies must therefore comply with the current rules in the Norwegian Accounting Act.

Changes to the EU taxonomy

One effect of the CSRD is that it extends the scope of the EU taxonomy, so that the same companies that are subject to the CSRD will be covered by the EU taxonomy's reporting requirements. Several of the proposed changes to the CSRD are therefore also proposed for the EU taxonomy, including amended threshold values and the provision on voluntary reporting. In addition, several changes are proposed specifically to the EU taxonomy. Key amendments may be summarised as follows:

• Revised threshold values: The European Commission proposes the same amendments to the threshold values for the taxonomy as for the CSRD, so that the scope of the CSRD and the EU taxonomy aligns. This implies that companies with fewer than 1,000 employees now fall outside the scope of the EU taxonomy. If the company has more than 1,000 employees and a turnover of more than EUR 450 million, the company is fully subject to reporting under the EU taxonomy. However, for companies with more than 1,000 employees and an annual turnover of less than EUR 450 million, the European Commission proposes a so-called opt-in regime. This implies that the reporting obligation only applies when the company claims that the activities are fully or partially in accordance with the EU taxonomy. The company should then report on turnover and CapEx KPIs and may choose to report on OpEx KPIs.
• Revision of the reporting templates: The European Commission proposes to simplify the reporting templates. For instance, the number of data points are reduced by 70%.
• Exemption for non-essential activities: The proposal allows for a company to omit taxonomy assessments for non-essential financial activities. An activity is to be considered non-essential if the activity accounts for less than 10% of the company's turnover, capital expenditure or assets.
• Voluntary reporting and reporting on partial compliance: Companies that are not required to report under the EU taxonomy may still choose to prepare taxonomy reports on a voluntary basis, as well as reporting on partial compliance with the EU taxonomy. Such voluntary reporting may have positive reputational and financial effects (e.g. sustainable financing).

Next steps in the EU

The Council of the EU and the European Parliament are currently negotiating the proposed Omnibus amendments. The Council adopted its negotiating mandate on 23 June 2025, while the European Parliament's negotiating mandate is expected in October 2025. The Council supports the Commission's proposal to raise the employee threshold. Additionally, the Council proposes to increase the annual turnover threshold from 50 million euros to 450 million euros. This represents a further narrowing of the scope of the CSRD compared to today.

The negotiations ("trilogies") between the Council, the Parliament and the Commission are scheduled from October to December 2025. The aim is for the Omnibus package to be adopted by the end of 2025, but it is possible that this may not occur until early 2026. Once the EU has agreed on the proposal, the Norwegian government will assess how potential amendments will be implemented into Norwegian law. This means that there still may be changes to the proposal. It is therefore important to stay updated on any developments.

Summary

If the Omnibus proposal is adopted, the reporting obligation will lapse for a number of companies that are currently subject to the CSRD and the taxonomy. If adopted, approximately 80% fewer companies in the EU will be subject to sustainability reporting obligations.

For the time being, it is uncertain how many actors in the real estate industry who will choose to report on a voluntary basis. However, there are indications that voluntary reporting could strengthen a company's market position, as tenants, insurers, lenders and other stakeholders demand such information. This is also illustrated by the fact that several of the market-leading Norwegian actors in the real estate industry appear to be integrating sustainability reporting into their operations.

Read Akershus Eiendom's ESG-analysis here: Market Views, June 2025 | ESG: Green Pause for Commercial Real Estate?

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