Eurogas Response to the Omnibus Simplification Package (CSRD, CS3D and EU Taxonomy)

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Eurogas welcomes the European Commission’s Omnibus Simplification Package, amending the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CS3D) and the Taxonomy Regulation. This initiative reflects a strong commitment from policymakers to actively engage with the EU industry to reduce administrative, regulatory and reporting burdens for businesses. It allows companies to focus their resources on innovation and competitiveness, while continuing to support the European Union’s decarbonisation objectives.

However, despite the revisions, certain unnecessary burdens on companies persist and should be addressed.

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Recommendation overview:

On the Corporate Sustainability Reporting Directive (CSRD)

1. The revision of the ESRS is welcome, but it must be carried out carefully to ensure the ESRS are fit for purpose.
2. Removing sector-specific standards is a positive step and should be supported by the EP and Council.
3. The amendments on limited and reasonable assurance are welcomed, although additional non-binding guidance is needed.
4. The new value chain cap is a positive step, but its impact remains unclear.
5. Measures to simplify the Taxonomy are welcomed, but they don’t go far enough.

On the Corporate Sustainability Due Diligence Directive (CS3D)

1. The focus on direct business partners is positive, but indirect obligations remain vague.
2. Amendments to Climate Transition Plans do not deliver the needed legal clarity.
3. The removal of mandatory business termination reflects a more pragmatic approach to supply chain management.
4. Revisions to EU-wide civil liability rules are positive, but additional adjustments are needed.
5. Lack of clarity in Article 9 on the prioritisation and prevention of adverse impacts might result in inconsistent implementation.
6. Narrower stakeholder definition is welcome, but consistency is lacking throughout the text.
7. The removal of the minimum fine cap is welcomed, but further guidance is needed to ensure consistent implementation across Member States.
8. Greater efforts are needed to avoid fragmented implementation of Due Diligence obligations across the EU.