Omnibus package 2025: simplifying the Carbon Border Adjustment Mechanism and sustainability reporting in the EU

On 26 February 2025, the European Commission adopted the first Omnibus legislative package, a landmark move to simplify EU sustainability-related regulations while preserving climate ambition. The most substantial impacts are seen in the Carbon Border Adjustment Mechanism (CBAM) and the Corporate Sustainability Reporting Directive (CSRD), both of which are being amended to reduce administrative burdens—particularly for small and medium-sized enterprises (SMEs).

This article outlines the major technical changes, with a specific focus on CBAM and cross-references amendments to the CSRD and Corporate Sustainability Due Diligence Directive (CSDDD), based on five legislative documents published alongside the package.

Simplifying the CBAM: introduction of a new de minimis threshold

Previous issue:

The original CBAM Regulation (EU) 2023/956 imposed uniform reporting and financial obligations across all importers of CBAM goods, regardless of the volume of imports. This created excessive burdens, especially for small and occasional importers.

New solution:

The Omnibus package introduces a mass-based de minimis threshold of 50 tonnes per year for selected CBAM goods (aluminium, cement, fertilisers, iron, and steel). Importers below this threshold are exempt from administrative CBAM obligations (excluding financial obligations, if any).

Regulatory detail:

• The exemption applies per importer, per calendar year.
• Hydrogen and electricity are excluded due to their unique import profiles.
• Default values are refined to ensure consistency in emission intensity calculation.

Impact:

Example:

An importer sourcing 40 tonnes of aluminium annually—representing low embedded emissions—is now fully exempt from CBAM reporting and verification. Previously, they would need to submit quarterly emissions reports, purchase certificates, and pay administrative costs exceeding the value of the goods imported.

Methodology: how the 50-tonne threshold is justified

The 50-tonne threshold is calculated using a mass-based formula that ensures 99% of emissions remain within CBAM’s regulatory scope:

Where:

• Q_i: total imported volume by importer i
• Emi_i: emissions associated with those volumes
• Q: the threshold that excludes low-emission importers

This approach avoids manipulation through consignment splitting (a risk in value-based thresholds) and is consistent with environmental integrity goals.

Technical simplifications beyond the de minimis threshold

1. Streamlined verification obligations

• Verification now only applies to actual emission values.
• Default emissions data (without markups) no longer requires independent verification.

2. Flexible reporting delegation

• Authorised CBAM declarants may delegate reporting tasks via the CBAM Registry.
• Enables third-party digital service providers to manage submissions under declarant control.

3. Simplified financial liability calculations

• Default carbon prices will be pre-calculated by the Commission.
• Repurchase limits and certificate sales rules are modified to accommodate 2027 as the first year of financial adjustment.

4. Adjusted deadlines

• Annual CBAM declarations are now due later in the year, allowing more time for emissions and pricing data collection.

Broader context: simplifications in the CSRD and CSDDD

Although CBAM takes center stage, the Omnibus package also introduces significant changes to corporate sustainability reporting and due diligence laws:

The 2025 Omnibus legislative package marks a substantial shift in the EU’s sustainability policy architecture. While maintaining climate ambition and environmental protection, it pragmatically addresses the operational bottlenecks voiced by stakeholders.