ESG: the omnibus content directive top ten things – a client note

In February 2025, as part of the EU’s simplification agenda, the European Commission proposed a series of amendments (Omnibus I) to two core components of its sustainable finance framework:

• the Corporate Sustainability Reporting Directive (CSRD) and
• the Corporate Sustainability Due Diligence Directive (CSDDD).

Omnibus I included the Content Directive, which makes extensive amendments to the CSRD and the CSDDD.

The Content Directive has now been published in the Official Journal and will enter into force on 16 March 2026 – Member States must transpose its provisions into national law by 19 March 2027.

Our client note below sets out what we consider to be the Top Ten Things which in-scope entities should think about in relation to the changes made by the Content Directive, looking at the following topics:

1. Undertakings in scope

2. Third country undertakings

3. Value chain cap

4. Specific exemptions from reporting

5. ESRS

6. Group restructures

7. Voluntary standards

8. Requirements for audit firms

9. Assurance standards

10. CSDDD