The Commission Work Programme 2025: What’s Next for the Omnibus?

Updates in relation to the EU’s proposed sustainability ‘omnibus’ package seem to be coming thick and fast, although distinguishing between what is rumour and what is actually being planned, whilst we await further details from the Commission, can be challenging. As a result, all eyes were on the Commission’s 2025 Work Programme, published on 11 February, which sets out the EU’s main strategies, action plans and legislative initiatives for the year ahead.[1]

Unsurprisingly, the sustainability omnibus proposals featured, under the thematic heading of ‘Simplifying rules and effective implementation’. The Work Programme provides a useful timeline setting out when the sustainability and other omnibus packages are expected to be delivered. Key dates (which all form part of the EU’s simplification efforts) are as follows. Updates that relate specifically to sustainability are highlighted in green: 

The omnibus package on sustainability will include proposals to streamline and simplify “sustainability reporting, sustainability due diligence and taxonomy”, which is widely expected to include proposals to simplify the Corporate Sustainability Reporting Directive, Corporate Sustainability Due Diligence Directive and EU Taxonomy. The revision of the Sustainable Finance Disclosure Regulation – a process which started in 2023, with details due to be published in Q4 2025 – will be addressed simultaneously with the general simplification agenda and should therefore be seen in that light. 

A roundtable took place earlier in February in Brussels, hosted by the Commission, with representatives from industry, NGOs and other stakeholders in attendance, to discuss the sustainability simplification proposals, but there has been no official confirmation of what was said. More concrete proposals have been developed in relation to the EU Taxonomy: the EU Platform on Sustainable Finance published a report earlier this month which recommends reducing the reporting burden under the Taxonomy by more than one third, including, for example, by introducing a lighter “do no significant harm” compliance assessment process, and adopting a simplified approach to the Taxonomy for listed SMEs.[2]

It is important to note, however, that the omnibus packages do not mean that the Commission plans to jettison sustainability laws in their entirety. The Work Programme makes note of Europe’s goal to become the first climate-neutral continent by 2050, and outlines that a proposed 90% emission-reduction target for 2040 will be enshrined in the EU’s European Climate Law. Annex III to the Work Programme lists proposals pending agreement by the European Parliament and the Council, which are not being withdrawn, and includes, amongst others, the Green Claims Directive. A challenge that may be front of mind for some is how to balance the push towards competitiveness and decarbonisation in the short, medium and long terms. 

The Industrial Decarbonisation Accelerator Act, together with the Clean Industrial Deal and proposed simplification of the Carbon Border Adjustment Mechanism (CBAM) (the latter may form part of the first omnibus package, but this has not been confirmed), may be seen by some as embodying the Commission’s drive to harmonise robust environmental ambition with pragmatic industrial policy. For example, the Act seeks to fast-track innovative decarbonisation technologies and secure vital investments. It may target sectors such as steel, cement and chemicals by supporting pilot projects in carbon capture, utilisation and storage, or transitioning from conventional blast furnaces to green hydrogen-based direct reduced iron processes, thereby providing a pathway for emissions reductions. However, proposals to streamline permit granting and other authorisations in order to speed up processes may risk weakening environmental protections. 

Like other aspects of the omnibus proposals, the CBAM proposals – the details of which are yet to be set out – could introduce a more simplified and streamlined reporting framework for importers, but doing so would likely reduce the CBAM’s coverage. Meanwhile, the Clean Industrial Deal (which is not labelled as a simplification effort, but is mentioned in the Work Programme) proposes an overarching framework that aims to integrate environmental integrity with economic vitality. It envisages nurturing cross-sector partnerships relating to energy efficiency, renewable energy adoption and integrating circular economy principles, with the intention of reinforcing Europe’s industrial competitiveness in a decarbonising global market.

The sustainability simplification aspects of the Work Programme present a calibrated vision that attempts to reconcile environmental ambition with the realities of industrial competitiveness, against a backdrop of an increasingly complex global market. The devil will be in the detail, however, as to whether the omnibus proposals are able to achieve these potentially competing aims.

[1]Commission work programme 2025 - European Commission

[2]Simplifying the EU Taxonomy to Foster Sustainable Finance