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EU Co-Legislators Strike Provisional Omnibus I Deal to Narrow CSRD and CS3D, Delay Compliance

Company obligations would not apply until mid-2029 if the deal is adopted.

Overview

  • The provisional agreement trims CSRD coverage by removing listed SMEs and financial holding undertakings and by setting new thresholds of at least 1,000 employees and over €450 million in net turnover.
  • For CS3D, the deal raises entry thresholds to 5,000 employees and €1.5 billion in net turnover and drops the requirement for companies to adopt a climate transition plan.
  • Penalties for CS3D non-compliance would be capped at 3% of net worldwide turnover, with guidance to be developed by the European Commission and member states.
  • The transposition deadline moves to 26 July 2028, implying company compliance by July 2029, with transitional exemptions in 2025–2026 for early CSRD reporters.
  • The package remains a provisional accord that must be formally endorsed by the European Parliament and the Council before becoming law.