CSRD: Conclusion of trilogue negotiations on the substance proposal

On 16 December 2025, the EU Parliament voted in favour of the provisional agreement reached on 9 December 2025 between the EU Parliament and the EU Council on the EU Commission’s proposal for an amending directive to simplify sustainability reporting in accordance with CSRD and due diligence obligations in accordance with CSDDD. The Committee of Permanent Representatives (COREPER) of the EU Council had already announced on 10 December 2025 that the EU Council would also vote in favour of the provisional agreement if the European Parliament did so.

This concludes the trilogue negotiations, and the new EU regulations can now be published in the EU Official Journal and transposed into national law by the EU Member States.

The content relates in particular to the following points:

• Accounting Directive/CSRD: companies subject to reporting requirements must have more than 1,000 employees and more than €450 million in sales revenue
• CSDDD: companies subject to the directive must have more than 5,000 employees and more than €1.5 billion in turnover.

A public press conference on this topic will be held on 16 December 2025 at 3 p.m.

Background:

On 26 February 2025, the European Commission published the Omnibus I package with proposals to reduce bureaucracy for companies. These proposals focus in particular on the so-called Substance Proposal to amend the Accounting Directive (Directive 2013/34/EU), the CSRD (Directive (EU) 2022/2464) and the CSDDD (Directive (EU) 2024/1760) as well as the Audit Directive (Directive 2006/43/EC). The aim of the Substance Proposal with regard to amendments to the Accounting Directive is to achieve significant simplifications in the requirements for sustainability reporting. Formally separate from this, a proposal was submitted to postpone the temporal scope of application of the CSRD and the CSDDD (‘Stop-the-Clock’ Directive), which has now been published as Directive (EU) 2025/794 in the EU Official Journal.

The DRSC will publish a briefing paper on the new EU regulations in the near future.