CSRD & CSDDD Omnibus: What It Means for Retailers

The European Commission adopted an Omnibus simplification package in February 2025, and a provisional political agreement between the European Parliament and Council was reached in December 2025. The package does not replace the CSRD and CSDDD frameworks, it recalibrates scope, timing and reporting complexity.

in short:

• CSRD revised scope (1,000+ employees + €450m turnover) now incorporating non-EU threshold.
• CSDDD confirmed thresholds now incorporating a phased application (2027–2029)

But for retailers, the reality is more nuanced.

While the Omnibus package may reduce the number of organisations directly captured under CSRD and extends the timeline for CSDDD, however it doesn't reduce the need for structured supply chain transparency and defensible ESG governance.

What Has Changed Under the Omnibus package?

While final legislative detail continues to move through EU processes, several core changes are clear and materially impact retailer exposure. The simplification focus has been heavier on CSRD scope and ESRS streamlining, than CSDDD.

1. CSRD: Narrowed Scope

Under the original framework (previously outlined in our CSRD factsheet), CSRD applied broadly to large EU companies and certain non-EU entities with significant EU turnover.

Under the latest political agreement between the European Parliament and Council (December 2025), CSRD reporting would apply to EU companies employing on average;

• more than 1,000 employees and
• with net annual turnover exceeding €450million.

For non-EU companies, reporting would apply where they generate more than €450 million net turnover within the EU, subject to the presence criteria defined in the directive (such as qualifying subsidiariesor branches).

This represents a significant narrowing of scope compared to the original framework, which captured a broader range of large and listed companies.

Retailer impact:
If your organisation falls below both the 1,000 employee threshold and the €450million turnover threshold, you may no longer be directly required to produce CSRD-aligned sustainability statements under the revised scope.

However, if you supply into an in-scope organisation, ESG data requests will continue.

2. CSDDD: Clarified Thresholds & Phased Application

As previously outlined in our CSDDD Factsheet, the directive still applies to:

• 1,000+ employees, and
• €450m+ global turnover

The Omnibus package impacts the timeline and phasing; with obligations beginning in July 2027 for the largest companies and extending to all other companies in scope by July 2029.

Impacts:

• Retailers below these thresholds are unlikely to be directly in scope.

• Retailers above them, particularly EU-headquartered groups, should assume due diligence obligations will apply.

Importantly, CSDDD public communication requirements are satisfied through CSRD reporting where applicable, further reinforcing how closely the two frameworks are linked.

3. Reporting Simplification - Not Removal

However, for those still in scope, the obligation to demonstrate credible governance, risk assessment and mitigation remains unchanged.

Direct vs Indirect Impact: Why Retailers Are Still Affected

For many retailers, the key shift is not removal of obligation, but redistribution of pressure. Supply chain expectations will continue. Large in-scope organisations must still:

• Map supply chains
• Identify human rights and environmental risks
• Demonstrate mitigation and remediation
• Collect structured ESG data from suppliers

In practice, this means retailers supplying into EU markets may still face:

• ESG questionnaires
• Contractual sustainability clauses
• Certification verification requests
• Audit and corrective action reportingrequirements

The regulatory burden may move upstream, but operational pressure will flow downstream.

Retailer Self-Assessment: Are You Exposed?

Sustainability managers and executives should ask:

Are We Directly in Scope?

• Do we employ on average more than 1,000 employees?. For CSDDD specifically: measured over two consecutive financial years)
• Do we exceed €450 million net annual turnover?
• If we are a non-EU company, do we generate more than €450 million net turnover within the EU. For CSRD specifically; do we also meet the relevant EU presence criteria?. For CSDDD specifically; measured over two consecutive financial years?

If yes: prepare for formal sustainability reporting obligations under CSRD, and Human rights and environmental due diligence alignment under CSDDD.

If no: move to the next question.

Are We Indirectly Exposed?

• Do we supply to EU-based brands or retailers?
• Are customers requesting ESG data?
• Are sustainability clauses embedded incontracts?
• Are investors requesting structured disclosures?

If yes: operational readiness may still be required.

What Sustainability Leaders Should Do Now

Strengthen Supply Chain Visibility

Move beyond Tier 1. Ensure suppliers declare:

• Factory locations
• Production routes
• Lower-tier sourcing and services
• Valid certifications

Embed Risk-Based Due Diligence

CSDDD follows a prioritisation model based on severity and likelihood. Retailers should:

• Identify high-risk operations
• Conduct in-depth assessments where required
• Develop corrective action plans
• Track remediation progress

Align Reporting with Operational Reality

CSRD reporting and CSDDD due diligence are interconnected. Data collection must align with:

• Risk identification
• Preventative action
• Mitigation measures
• Remediation tracking

Under CSRD, sustainability statements must cover:

• Environmental standards (E1–E5)
• Social standards (S1–S4)
• Governance standards (G1)

Reporting must reflect real governance processes, not standalone disclosures. Without operational alignment, reporting could become vulnerable.

How Segura Supports Retailers

Whether directly regulated or responding to commercial pressure, retailers need structured infrastructure. Segura enables retailers to:

Map Multi-tier supply chains - Identify actors, products and services across complex value chains, tracked at order level where required.

Integrate Risk Data - Overlay third-party risk indicators to prioritise high-risk operations.

Manage Compliance & Corrective Actions - Track audits, self-assessment questionnaires and corrective action plans in a centralised system.

Support CSRD Data Collection - Capture supply chain data required for ESRS reporting, including value chain impacts.

The result is not simply compliance readiness but commercial resilience.

The Strategic Takeaway

The Omnibus package narrows direct scope (CSRD) and adjusts timelines (CSDDD) under the current political agreement, but it does not change the direction of trave

Sustainability governance is becoming embedded in procurement, investor scrutiny and regulatory oversight. Retailers that use this period to:

• Centralise supplier data
• Strengthen due-diligence processes
• Align reporting with operations

will be better positioned, commercially and reputationally, than those who wait. Because when scrutiny comes, the question will not be: “Were you technically in scope?”

It will be: “Can you demonstrate what you knew, and what you did?”

Regulatory status: This article reflects the European Commission’s February 2025 Omnibus proposal and the provisional political agreement reached between the European Parliament and Council in December 2025. Final legislative texts remain subject to formal adoption and publication in the Official Journal of the European Union.