A Guide to EU Omnibus Directive for the Aviation Sector

EU Omnibus directive feature image

In 2025, the European Commission launched the Omnibus Directive, a crucial step toward reforming and simplifying the EU’s sustainability regulatory framework.

This guide provides aviation stakeholders with a detailed breakdown of what the EU Omnibus Directive entails, why it matters, how it aligns with international standards, key implementation timelines, and actionable steps to prepare.

This articles covers:

What Is the EU Omnibus Directive?

The EU Omnibus Directive is a legislative initiative introduced by the European Commission on 26 February 2025, designed to simplify and harmonize the EU’s complex framework of sustainability-related regulations.

It proposes key amendments to existing legislation including the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Taxonomy Regulation. The directive seeks to reduce administrative burden, enhance legal clarity, and make compliance more manageable for companies operating within the European Union, without compromising on the EU’s ambitious climate and sustainability objectives 1.

For aviation companies, which often operate across multiple jurisdictions and maintain intricate supply chains, this simplification can offer both relief and new compliance responsibilities. Notably, one major proposed change under the Omnibus Directive is the adjustment of reporting thresholds under the CSRD. Originally set to apply to nearly 50,000 companies across the EU, the amendments may significantly reduce this number, exempting thousands of smaller firms from immediate obligations 2. It’s estimated the number of companies required to report could fall by up to 80% across the EU 6.

What Does the Omnibus Directive Entail?

The Omnibus directive introduces amendments to five major frameworks: CSRD, CSDDD, EU Taxonomy Regulation, CBAM, and the InvestEU Regulation.

Key Highlights

1. CSRD & CSDDD Amendments

  • Reporting Delays: CSRD reporting for companies due in 2026–2027 is postponed to 2028. CSDDD application is delayed by one year 7,8.
  • Higher Thresholds: CSRD will apply only to companies with over 1,000 employees and either €50 million in turnover or €25 million in assets—excluding about 80% of previously in-scope firms. For non-EU companies, the EU revenue threshold rises from €150 million to €450 million 7,9.
  • Simplified Disclosures: Fewer data points and streamlined templates across CSRD, CSDDD, and Taxonomy reporting 8.

2. EU Taxonomy Changes

  • Materiality Thresholds: New thresholds for required reporting, and the option to report partial alignment with Taxonomy activities.
  • Reduced Complexity: Simplified DNSH criteria and disclosure templates. Easier calculations for financial institutions, including the Green Asset Ratio (GAR) 8.

3. CBAM (Carbon Border Adjustment Mechanism) Thresholds

  • Mass-Based Thresholds: Replacing the €150 value threshold, a new 50-tonne rule would exclude many small importers while still capturing 99% of embedded emissions 7.
  • Operational Flexibility: Importers can begin purchasing certificates from February 2027, with new delegation and reporting options 7.

4. InvestEU Updates

  • Lighter Reporting: Reduced reporting frequency and data requirements.
  • Increased Guarantee Capacity: €2.5 billion in additional EU guarantees to unlock €50 billion in new investment 8.

Why It Matters for Aviation Stakeholders

The aviation sector is under increasing scrutiny for its environmental impact and supply chain ethics.

The Omnibus Directive affects aviation stakeholders in several ways:

  • Expanded Reporting Obligations: The CSRD reforms may adjust thresholds and reporting scopes, potentially requiring more aviation entities to disclose detailed environmental, social, and governance (ESG) data.
  • Enhanced Due Diligence: Changes to the CSDDD could introduce clearer, potentially broader, responsibilities for identifying and addressing sustainability and human rights risks within global aviation supply chains.
  • Investment Signal Shifts: Modifications to the EU Taxonomy Regulation may redefine which aviation activities are considered sustainable, influencing investment flows and financing conditions 3.

Failure to adapt to these changes could lead to reputational damage, loss of access to sustainable financing, and regulatory penalties.

 

How EU Omnibus Aligns with Global Standards and Legislation

The Omnibus Directive is designed to ensure compatibility with global sustainability frameworks and initiatives:

  • Task Force on Climate-related Financial Disclosures (TCFD): Supports greater transparency and comparability in climate-related financial risks and opportunities.
  • International Sustainability Standards Board (ISSB): Facilitates alignment with global baseline sustainability disclosure standards.
  • International Civil Aviation Organization (ICAO): Reinforces global commitments such as the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) 4.

This alignment ensures European aviation firms are not at a disadvantage internationally, and supports consistency in global sustainability metrics and expectations.

Timeline with Key Milestones

  • 26 February 2025: European Commission publishes the Omnibus Directive proposals 1.
  • April 2025: “Stop-the-Clock” Directive is adopted, pausing certain reporting deadlines to allow for alignment 5.
  • Q3–Q4 2025: Stakeholder consultations and negotiations among EU institutions.
  • Q1 2026: Expected adoption of final legislation by the European Parliament and Council.
  • 2027 and beyond: Phased implementation begins across member states, with periodic review mechanisms.

Staying aware of these dates is critical for timely compliance planning and resource allocation.

Navigate the Omnibus Directive with PACE

Leverage PACE to deliver compliant, verifiable emissions data that supports CSRD and CSDDD reporting under the EU Omnibus Directive.

Contact Us

 

 

How Aviation Stakeholders Can Prepare

The Omnibus Directive also proposes postponing the application of all CSRD reporting requirements by two years for companies that have not yet begun reporting. This transition period offers aviation stakeholders valuable time to strengthen internal systems, enhance ESG data quality, and conduct robust materiality assessments.

  • Conduct a Regulatory Impact Assessment: Identify how the proposed amendments affect your operations, especially in terms of reporting and supply chain obligations.
  • Conduct a Double Materiality Assessment: Leverage the delayed reporting timeline to conduct a thorough assessment of both financial and impact materiality in line with CSRD and ESRS requirements.
  • Recalibrate Reporting Processes: Align systems with the expected simplifications under CSRD and the EU Taxonomy, including the European Sustainability Reporting Standards (ESRS).
  • Reassess Supply Chain Due Diligence: Evaluate current supplier practices and risk management approaches in light of potentially broader obligations under CSDDD.
  • Engage with Policymakers and Industry Groups: Participate in consultations to shape the final legislation and stay informed of evolving expectations.
  • Accurate Carbon Data for Compliance: Platforms like PACE support with precise carbon emissions tracking and reporting.

 

References

  1. European Commission. (2025, February 26). Commission simplifies rules on sustainability and EU investments. https://finance.ec.europa.eu/publications/commission-simplifies-rules-sustainability-and-eu-investments-delivering-over-eu6-billion_en
  2. White & Case. (2025). EU Omnibus Package: 10 things you should know. https://www.whitecase.com/insight-alert/eu-omnibus-package-10-things-you-should-know-about-proposed-changes-key
  3. Ricardo. (2025). All aboard the EU Omnibus. https://www.ricardo.com/en/news-and-insights/industry-insights/all-aboard-the-eu-omnibus
  4. International Civil Aviation Organization (ICAO). (n.d.). Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). https://www.icao.int/environmental-protection/CORSIA/Pages/default.aspx
  5. Norton Rose Fulbright. (2025). Brief Update: Omnibus ‘Stop the Clock’ Directive comes into force. https://www.nortonrosefulbright.com/en/knowledge/publications/391bb931/brief-update-omnibus-stop-the-clock-directive-comes-into-force 
  6. de Jongh, M. (2025, June 4). How will the sustainability of the EU’s omnibus transform your CSRD journey? The Independent. Retrieved from https://www.independent.co.uk/news/business/business-reporter/sustainability-eu-omnibus-csrd-business-b2761265.html
  7. Accountancy Europe. (2025, May). Omnibus explained: Key changes to CBAM. Retrieved from https://accountancyeurope.eu/publications/omnibus-explained-key-changes-to-cbam
  8. Regulation Tomorrow. (2025, March). Commission adopts omnibus sustainability and investment packages. Retrieved from https://www.regulationtomorrow.com/france/commission-adopts-omnibus-sustainability-and-investment-packages/
  9. Grant Thornton. (2025). The Omnibus Package: EC releases proposals. Retrieved from https://www.grantthornton.global/en/insights/articles/the-omnibus-package-ec-releases-proposals/
Share this article