EU Sustainability Regulations as of November 2025: What SMEs Need to Know
- uIMPACT
- Oct 31
- 3 min read
Updated: Nov 10
The European Union’s sustainability agenda continues to evolve, with reforms aimed at balancing environmental ambition and business practicality. In February, the Commission introduced the Omnibus proposals —meant to simplify and realign EU rules.
Since then, the EU Parliament has adopted parts of the Omnibus package, but several of its key elements remain under negotiation.
A vote on the Legal Affairs Committee’s (JURI) mandate regarding simplified rules for sustainability reporting and due diligence obligations on October 22, 2025, rejected the simplified rules for sustainability reporting and sent the proposed simplifications for sustainability reporting and due diligence back for further debate.
A new vote on the package is scheduled for November 13, 2025, at which point the final text could undergo significant adjustments, creating uncertainty for companies regarding compliance timelines and the scope of future requirements.
A Brief Recap: The Omnibus package
In February, the European Commission rolled out the Omnibus package to reduce administrative burdens without sacrificing the integrity of sustainability rules.
Here is a list of the main changes proposed in the Omnibus package in February:
CSRD (Corporate Sustainability Reporting Directive): trimming the number of companies under full reporting obligation, and introducing voluntary reporting standards for smaller firms.
CSDDD (Corporate Sustainability Due Diligence Directive): creating tiered obligations depending on company size.
CBAM (Carbon Border Adjustment Mechanism): exemptions and clarifications to ease the burden on small importers.
EU Taxonomy: simplifying technical criteria and setting thresholds to ease reporting complexity.
These changes promised cost savings, mobilization of investment, and better alignment of sustainability requirements with business capability.
What’s New as of October 2025
Developments since the Omnibus proposal was introduced in February include:
Partial adoption via the Stop‑the‑Clock Directive: This directive has been formally adopted and must be transposed by Member States by 31 December 2025. It delays certain CSRD and CSDDD obligations (especially for Wave Two and Three companies) until 2028.
Quick‑fix delegated acts for ESRS: On 11 July 2025, the Commission adopted delegated changes to ESRS (European Sustainability Reporting Standards) allowing relief for 2025–2026 disclosures and extending phase‑in provisions to all Wave One companies.
Extended timeline for ESRS revision: EFRAG's deadline for sending its technical advice on simplified ESRS has been moved from October to 30 November 2025. The public consultation period for exposure drafts was also extended to 60 days (end‑July to end‑September).
Council & Parliament mandates solidified: Member States, through the Council, have agreed on their negotiating position on simplifying CSRD and CSDDD obligations.
Second Omnibus draft underway: A separate draft package is being prepared to further streamline interface rules across CSRD, CSDDD, CBAM, and Taxonomy.
What to Expect in November–December 2025
Over the next two months, several pivotal events and decisions are anticipated. Companies should watch for:
Dates | Event | Why It Matters for SMEs |
30 Nov 2025 | EFRAG releases final ESRS technical advice | Clarifies simplified reporting standards, guiding what data SMEs may need to provide to clients or for voluntary reporting. |
Nov–Dec 2025 | Trilogue negotiations conclude | EU Parliament, Council, and Commission finalize Omnibus legislation, setting final thresholds, scope, and proportionality rules. |
By 31 Dec 2025 | Member States transpose Stop‑the‑Clock directive | Confirms delayed reporting deadlines for CSRD/CSDDD; SMEs can plan compliance with greater certainty. |
Late 2025 / Early 2026 | Final votes and adoption of Omnibus text | Determines which simplifications are legally binding; affects reporting obligations for SMEs and mid-sized suppliers. |
Late 2025 / Early 2026 | Publication of guidance & implementing acts | Provides clarity on assurance, materiality, and supply chain data requests—critical for SMEs preparing for future reporting. |
What This Means for SMEs
The partial adoption of Stop‑the‑Clock measures already provides relief from immediate administrative pressures, but the next two months will likely determine the final shape and timing of EU sustainability obligations.
In the next few months, SMEs should:
Watch for final thresholds to understand if and how they fall under reporting or due diligence obligations.
Track transposition of the Stop‑the‑Clock directive in their country to confirm delayed deadlines.
Prepare for updated supply chain data requests, which may still come from larger clients.
Build basic reporting and due diligence capabilities now to ensure smooth compliance once the full Omnibus reforms are adopted.
Start lightweight reporting and supply chain data collection to ensure quicker adaptation once the final legislation is adopted.
How can we help?
uIMPACT is a full-service provider of sustainability assessment, reporting, and management services. We help companies report on and meet the sustainability expectations of partners, clients, investors, banks, and regulations.
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