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    GN/2025/247- simplifying sustainability
    17 Dec 2025

    Today, the Council’s presidency and European Parliament’s negotiators reached a provisional agreement to simplify sustainability reporting and due diligence requirements to boost EU competitiveness. The agreement simplifies the directives on corporate sustainability reporting (CSRD) and corporate sustainability due diligence (CSDDD) by reducing the reporting burden and limiting the trickle-down effect of obligations on smaller companies.

    Next steps

    The provisional agreement must be now endorsed by the Council and the European Parliament before it is formally adopted by the two institutions. 

    In more detail:

     

    Corporate sustainability reporting directive

    On the CSRD, the compromise sees:

    • increase the employee threshold to 1000 employees and
    • net turnover threshold of over €450 million to alleviate further reporting burden and
    • to remove listed SMEs from the scope of the directive
    • agreed to exempt financial holding undertakings from the CSRD’s scope and agreed on a transition exemption for companies that had to start reporting from financial year 2024 (the so-called “wave one” companies) falling out of scope for 2025 and 2026.
    • introduces a review clause concerning a possible extension of the scope for both CSRD and CSDDD.

    Corporate sustainability due diligence directive

    Scope: While the CSDDD’s scope was not covered by the Commission’s proposal, the provisional agreement increases the thresholds to 5,000 employees and €1.5 billion net turnover. The co-legislators considered that such large companies have the biggest influence on their value chain and are best equipped to make a positive impact and absorb the costs and burdens of due diligence processes.

    Identification and assessment of adverse impacts

    The Commission’s proposal limits the further assessment of the identification phase to the company’s own operations, those of its subsidiaries, and those of its direct business partners. The provisional agreement also removes this limitation. Instead, companies can focus on the areas of their chains of activities where actual and potential adverse impacts are most likely to occur. To provide companies with flexibility, when a company has identified adverse impacts equally likely or equally severe in several areas, they are given the ability to prioritise assessing adverse impacts which involve direct business partners. Furthermore, companies should no longer be required to carry out a comprehensive mapping exercise but instead conduct a more general scoping exercise. Companies are supposed to base their efforts on reasonably available information, which will reduce the trickle-down effect of information requests on smaller business partners.

    Climate transition plans

    The obligation for companies to adopt a transition plan for climate change mitigation has been removed.

    Civil liability, penalties and transposition

    The provisional agreement removes the EU harmonised liability regime and the requirement for member states to ensure that the liability rules are of overriding mandatory application in cases where the applicable law is not the national law of the member state. A review clause on the need for an EU harmonised liability regime has been inserted.

    When it comes to penalties, it was agreed on a maximum cap of 3% of the company’s net worldwide turnover with the Commission issuing the necessary guidelines in this regard.

    The transposition is postponed by a further year to 26 July 2028. Companies will have to comply with the new measures by July 2029.

    Action: Gafta will continue to monitor developments.

    Full details in the attached legislation and Council Press release:

    • Simplification: Council agrees position on sustainability reporting and due diligence requirements to boost EU competitiveness - Consilium
    • Simplification: Council agrees position on sustainability reporting and due diligence requirements to boost EU competitiveness (press release, 23 June 2025)
    • Directive on certain corporate sustainability reporting and due diligence requirements, Commission proposal, 26 February 2025

    Disclaimer
    All Gafta Circulars and Notices are provided to Members purely for the purposes of information. We have not taken any steps to verify the accuracy of the information provided and, accordingly, Members must obtain their own independent professional advice as to its content and effect. We cannot accept any liability, howsoever arising, for any loss or damage which may be caused by any reliance on any information contained in a Gafta Circular or Notice.

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