In recent years, the European Union has rolled out one of the most ambitious sustainability regulatory frameworks in the world.

Directives such as the CSRD, the CSDDD and the CBAM have placed companies at the heart of the ecological and social transition, assigning them a key role in emissions reduction, transparency and due diligence throughout the value chain. This regulatory expansion, however, has been accompanied by growing criticism from Member States and the business sector, which have warned about the complexity of the resulting framework, the overlap of obligations and its impact on European industrial competitiveness.

Sustainability cannot be built solely on increasingly complex regulatory frameworks, but rather on clear, coherent and applicable regulations.

It is in this context that the Omnibus Package has emerged: an initiative by the European Commission designed to review and adjust this regulatory framework without dismantling it. Far from constituting a single piece of legislation, the Omnibus acts as a cross-cutting amending instrument, introducing coordinated changes to several key components of the European ESG framework with the aim of aligning regulatory requirements with companies’ actual capacity to comply and with their potential impact.

Presented in February 2025, the Omnibus Package has progressed over the past year through an intense process of institutional negotiation. The positions of the Council and the European Parliament have gradually converged, leading to political agreements that significantly reshape both the scope and the intensity of corporate sustainability obligations in the European Union, particularly through amendments to the CSRD and the CSDDD.

CSRD: fewer companies in scope, greater focus on large organisations

The Corporate Sustainability Reporting Directive (CSRD), which replaces and expands the former Non-Financial Reporting Directive, was originally designed to extend sustainability reporting to tens of thousands of European companies. The Omnibus Package introduces one of its most significant changes here by redefining the applicability thresholds, with the aim of concentrating the most complex obligations on organisations with the greatest potential impact and the greatest capacity to generate comparable and verifiable information.

As a result, the obligation to report under the CSRD is now limited to companies with more than 1,000 employees and annual turnover exceeding €450 million. In the case of third-country companies, the directive applies where turnover generated within the European Union also exceeds this threshold.

The Omnibus Package represents a step in the right direction, opening the door to a more functional regulatory framework focused on the effective reduction of unnecessary burdens.

The Omnibus also introduces technical adjustments to the practical application of the CSRD, particularly with regard to the level of reporting detail and information from the value chain. The European Sustainability Reporting Standards (ESRS) remain the technical framework, but their application is more precisely defined, allowing data collection to be limited to those parts of the value chain where there is genuine influence or where clear material risks have been identified.
This approach has direct implications for the protection of small and medium-sized enterprises, which under the original design of the CSRD could have been subject to disproportionate obligations as suppliers to large companies. By linking information requests to materiality and actual influence, the Omnibus reduces the cascading effect and limits the systematic transfer of regulatory burdens to SMEs. It also explicitly recognises the possibility of using estimates, sectoral data or aggregated information where reliable primary data cannot be obtained, provided that this choice is duly justified.

At the same time, the Omnibus Package strengthens coherence between the CSRD and the EU Taxonomy, clarifying that the obligation to report under the CSRD does not automatically entail reporting with the same level of detail on taxonomy alignment. The scope of Taxonomy-related reporting must be aligned with the financial materiality of the company’s activities and their effective fit with the defined technical criteria.
Within this framework, the principle of double materiality remains a structural pillar of reporting, but its practical role as a prioritisation tool is reinforced. This allows companies to document why certain indicators or disclosures are considered relevant and others are not, avoiding a uniform approach that would require reporting information of limited significance from an impact or financial risk perspective.

CSDDD: more limited and gradual due diligence

The Corporate Sustainability Due Diligence Directive (CSDDD) has been one of the most controversial elements of the European ESG framework, both in terms of its scope and its legal implications. The Omnibus Package introduces substantial changes here, starting with a very restrictive redefinition of its personal scope of application compared with the directive’s original design, which covered companies with at least 1,000 employees and €450 million in turnover. The new framework limits its application to companies with more than 5,000 employees and global turnover exceeding €1.5 billion.

The Omnibus acts as a cross-cutting amending instrument, introducing coordinated changes to several key components of the European ESG framework.

Alongside this adjustment, the Omnibus redefines the material scope of due diligence, limiting enhanced obligations to established business relationships and to areas where adverse risks have been identified and are reasonably foreseeable. This enables companies to prioritise actions and focus resources, rather than deploying uniform controls across the entire value chain.

The Omnibus also removes the explicit obligation to adopt binding climate transition plans as part of CSDDD compliance and thoroughly revises the civil liability regime, limiting automatic exposure to claims and linking liability to the reasonableness of the measures adopted. The sanctions regime is also adjusted, setting caps at around 3% of global turnover and reinforcing the principle of proportionality.

From an institutional perspective, these changes are justified as a means of ensuring the directive’s legal, operational and economic viability. However, they have attracted criticism from social and environmental organisations, which argue that the reduction in scope and obligations may weaken its transformative potential.

Taxonomy and CBAM: continuity with technical adjustments

Although the main focus of the Omnibus Package has been on the CSRD and the CSDDD, the initiative also introduces relevant adjustments to other key instruments of the European sustainability framework, particularly the EU Taxonomy and the Carbon Border Adjustment Mechanism (CBAM), with the aim of improving internal coherence and reducing unnecessary administrative burdens.

In the case of the EU Taxonomy, the Omnibus does not alter the technical criteria for classifying sustainable economic activities, but it does more precisely redefine the scope and intensity of the associated reporting obligations. The new approach clarifies that not all companies required to report under the CSRD must do so with the same level of detail in relation to the Taxonomy.

In practice, a more selective and proportionate application of taxonomy reporting is introduced, linking the level of information required to the financial materiality of activities and their effective alignment with the defined technical criteria. This translates into greater flexibility when reporting key indicators (such as aligned CAPEX or OPEX) where the company’s activity cannot be clearly classified as eligible or aligned, or where such information is not financially material. The aim is to avoid duplication with the CSRD and reduce the production of complex information with limited analytical value.

The European Sustainability Reporting Standards (ESRS) remain the technical framework, but their application is more precisely defined.

As for the CBAM, its basic architecture is maintained as an instrument designed to prevent carbon leakage and ensure more balanced competitive conditions between European and non-EU producers. However, the Omnibus Package introduces technical and operational adjustments intended to facilitate its implementation, particularly with regard to administrative requirements for importers, the collection of data on embedded emissions and coordination with other EU climate instruments. These adjustments seek to improve the mechanism’s practical applicability without altering its core objective or environmental rationale.

Simplification or rollback?

The debate surrounding the Omnibus Package has often been framed in terms of simplification versus ambition. However, a technical reading of the set of amendments points to a different issue: the actual effectiveness of the regulatory framework. After several years of very intense regulatory expansion, the Omnibus responds to the need to correct dysfunctions identified in the practical application of certain obligations, particularly those that have generated duplication, high administrative burdens or limited results in terms of environmental and social impact.

From this perspective, the adjustments introduced do not necessarily imply abandoning the objectives of the European Green Deal, but rather an attempt to redirect regulatory efforts towards areas where they can generate a genuine transformative effect, avoiding a situation in which excessive complexity ultimately dilutes effectiveness or diverts resources towards purely formal compliance. The challenge will be to ensure that simplification does not lead to the creation of new instruments that are equally complex or impractical, reproducing under different formats the very problems now being addressed. Even so, the Omnibus Package represents a step in the right direction, opening the door to a more functional regulatory framework focused on the effective reduction of unnecessary burdens.

The Omnibus Package has progressed over the past year through an intense process of institutional negotiation.

From the perspective of Genesal Energy, this approach is particularly relevant for the European industrial fabric. Sustainability cannot be built solely on increasingly complex regulatory frameworks, but rather on clear, coherent and applicable regulations that allow companies to concentrate resources on the real improvement of their processes, products and value chains. When administrative burdens exceed operational capacity, there is a risk that sustainability becomes a purely documentary exercise, disconnected from the industrial transformation it is meant to drive.

Ultimately, the success of the Omnibus Package will not be measured solely by the number of obligations adjusted, but by its ability to strengthen the competitiveness of European industry while keeping long-term sustainability objectives firmly in sight. It is within this balance between ambition and applicability that much of the future of the European regulatory model — and its capacity to effectively support the transition towards a more sustainable economy — will be determined.

Sustainability is entering a new phase. After years of directives, reports, and standards, Europe has realised that reporting alone is not enough — what matters is not how much is reported, but how much is transformed. With the approval of the Omnibus Regulation, the European Commission is taking a decisive step in that direction, simplifying the way companies report their environmental, social, and governance performance so that sustainability regains the meaning it should never have lost: action.

Properly managed sustainability not only reduces costs or emissions — it also opens doors.

This regulation was not created to lower ambition, but to restore coherence. In recent years, the CSRD Directive and the European Sustainability Reporting Standards (ESRS) have raised the bar for corporate reporting, but in doing so, they also imposed a disproportionate burden on many SMEs. It’s not just about gathering information: the CSRD required companies to measure dozens of environmental, social, and governance indicators with the same level of detail as large corporations. For an industrial SME, that means allocating human and financial resources it may not have, creating complex management systems, investing in digital tracking tools, and training staff in methodologies that until recently were exclusive to multinational ESG departments. In practice, sustainability was starting to look more like an exercise in bureaucracy than a process of improvement, diverting attention from the real goal: reducing impacts and creating value.

The Omnibus Regulation, approved in 2025, aims to correct that course. Its goal is to simplify administrative burdens and focus on material indicators — those that truly reflect an organisation’s impact on its surroundings. It’s essentially the same approach that guides our evolution: data that inspire decisions, measurements that drive change, sustainability that translates into action.

Measuring What Matters — and Acting on What Can Be Measured

At Genesal Energy, we’ve always understood sustainability as a tool for innovation and improvement, not a reporting obligation. That’s why, even before the Omnibus Regulation came into force, we were already working under the principles it now promotes: prioritising what’s relevant, reducing complexity, and focusing management on tangible results.
The new European framework particularly strengthens three key areas — those that concentrate most of the changes introduced by the Omnibus Regulation:

• E1: Climate change. Updated requirements for measuring greenhouse gas emissions, improving energy efficiency, and advancing towards a genuine transition to clean energy.
• E5: Resources and circularity. Simplified indicators with greater emphasis on responsible use of materials, waste reduction, and the adoption of circular economy principles.
• S1: People and the value chain. Strengthened social aspects: training, occupational health and safety, and ethical management across the entire supply chain.

E1. Climate Change: More Efficient Energy, Lower Impact

Our commitment to climate action is reflected in the way we manage energy. At our facilities in Bergondo (A Coruña), we have developed a model that integrates renewable sources, smart storage, and consumption optimisation.

The photovoltaic façades and roofs of our B27 and B28 plants generate part of the electricity we consume. Thanks to OGGY, our energy management and storage system, we can monitor production, consumption, and energy flow in real time. Its algorithm automatically decides whether to self-consume, store, or feed energy back into the grid — optimising every kilowatt used.

The results are tangible:

• We have reduced our annual energy consumption by 27%.
• We have improved the energy efficiency rating of our facilities from Category E to B.
• We avoid more than 23 tonnes of CO₂ emissions per year.

These figures are more than indicators — they are proof that sustainability is also a matter of engineering. Our industrial complex now operates as a small microgrid: an energy ecosystem capable of producing, storing, and managing its own electricity efficiently and autonomously.

E5. Resources and Circularity: Designing for the Entire Lifecycle

In this new European context, responsible resource management has become more relevant than ever — and at Genesal Energy, we have long been working in that direction. Efficient use of materials, waste reduction, and the incorporation of circular economy criteria are at the core of our eco-design policy.

That’s why we implemented an eco-design management system certified under ISO 14006, which enables us to assess the impact of each component, material, or manufacturing process — and redesign wherever there’s room for improvement.

Simplify administrative burdens and focus on material indicators — those that truly reflect an organisation’s impact on its surroundings.

This work has led to concrete progress:

• Replacement of conventional materials with recycled or recyclable ones — for example, replacing metal parts with 3D-printed recycled polymers, reducing emissions linked to transport and processing.
• Incorporation of local suppliers (km 0) to cut the logistics footprint.
• Elimination of welding or painting processes in certain components, reducing emissions and waste.

Thanks to these actions, some components have reduced their carbon footprint by more than 80% compared to the original materials.
But eco-design goes beyond the technical aspect — it also transforms the way we communicate. Our eco-designed products include environmental data and comparisons that allow clients to understand the savings in emissions and materials compared to previous models. This transparency is part of our commitment: providing clear, useful, and verifiable data that reflect the positive impact of every improvement we make.

S1. People and Knowledge: Learning to Transform

Sustainability is not limited to technology or processes; it also has a human dimension that is essential for progress. At Genesal Energy, we understand that knowledge, education, and social collaboration are fundamental pillars for building a fair and lasting energy transition — and we channel that commitment through the Genesal Energy Foundation.
Through the Foundation, we promote educational, social, and environmental projects that reflect our understanding of sustainability as a shared effort between business and society. We carry out training and awareness activities on energy and environmental issues, support cultural and social initiatives in our local community, and collaborate with organisations working towards more balanced and sustainable development.

Efficient use of materials, waste reduction, and the incorporation of circular economy criteria are at the core of our eco-design policy.

Our goal is to create a positive impact that goes beyond industrial activity — contributing to people’s well-being and to the progress of the environment in which we operate. We believe sustainability begins in the factory, but only becomes meaningful when it’s shared — when knowledge, responsibility, and social action move forward together.

From Measurement to Action

Measurement only makes sense if it leads to action — and at Genesal Energy, we’ve been living by that principle for years. Our environmental policy and management systems — certified under ISO 14001, ISO 14006, ISO 45001, ISO 9001, and UNE 166002 — enable us to turn indicators into technical and business decisions.

We measure our emissions, consumption, and waste — but what matters most is what we do with that information: we select sustainable suppliers, redesign parts, optimise packaging, improve testing efficiency, and reduce impacts at every production stage. In our experience, industrial sustainability is managed with the same precision as any engineering process. It’s not a separate part of the business — it’s part of the way we design, manufacture, and operate.

The new European framework reinforces this vision. Properly managed sustainability not only reduces costs or emissions — it also opens doors. It allows us to access green financing, participate in European projects, and be chosen by clients who value vision and environmental commitment. Sustainability is no longer an obligation; it’s a credential — and a guarantee: the mark of a company that innovates, adapts, and embraces its role in the energy transition with coherence and responsibility.

That’s why we continue to work by a simple principle: less bureaucracy, more innovation; fewer papers, more clean energy; less noise, more consistency.
Europe’s energy transition will be built on data — but above all, on examples. And ours is that of an industrial SME that has decided to integrate sustainability into its DNA — not as a distant goal, but as a way of moving forward every day.