#31 - The EU Omnibus Package - What it means for business & biodiversity

Joshua Berger

CEO at BioInt | Transforming biodiversity impact & dependency measurement | Driving pragmatic & science-based actions for nature | The Biodiversity Footprint Intelligence Company | Views are my own

Published Mar 25, 2025

This thirty first issue of The Nature Intelligence Newsletter focuses on the so-called "Omnibus Package" proposed by the European Commission in February 2025. It covers:

The consequences of the proposal for the CSRD, CSDDD, EU Taxonomy and CBAM
An opinion on the risks for businesses deciding not to implement the CSRD as initially planned
An opinion on the Omnibus not being negative for business & biodiversity (and my qualification of this)

Introduction - the regulatory driver for biodiversity uptake

When I started focusing on biodiversity impact measurement back in 2018 (following 7 years in consulting, with a strong focus on biodiversity financing mechanisms and ecological restoration), one major pull for companies to get interested in biodiversity was the expected Corporate Sustainability Reporting Directive (CSRD). Another was the update of the 10-year global goals for biodiversity. This update was expected in 2020 during biodiversity's COP15 (the Conference of the Parties to the Convention on Biological Diversity, the biodiversity COP, happens every 2 years).

Then covid happened and COP15 was delayed to 2022.

But still, from 2018 to 2022, momentum grew very strongly as the rising interest from companies coincided with significant methodological developments from tool developers and data providers.

Fast forward to 2025: the Omnibus proposal from the European Commission will change the disclosure requirements related to biodiversity in the CSRD. What can we expect from it? What will be its influence on corporate actions for biodiversity?

In this issue, I share a factual overview of the Omnibus package by David Carlin , and two opinion pieces by Anna Krotova and Dr Michael Burgass , on which I’ll also react.

The facts – what’s in the Omnibus proposal

As a reminder, the Omnibus requires to go through the European Parliament and Council, as highlighted by Anna Krotova in her post (see below and this article), that may take several years (it usually takes 2 years).

Opinions

Increased risks of non-compliance?

By trying to reduce a supposedly high burden on companies, the European Commission might be counterproductive, increasing uncertainties and legal risks.

I share Anna’s analysis.

To put things into perspective, financial accounting usually employs several times more people than sustainable development teams within companies, just to comply with financial accounting rules. Requiring more sustainability reporting (than today's) from companies seem entirely reasonable, given that those information are required to ensure our societies and economies have a planet over which they can operate in coming years!

The European Union is not only creating regulatory uncertainties but also missing an opportunity to define the rules globally and set a level-playing field for its companies, increasing their competitiveness.

Not so bad for corporate nature & biodiversity?

I agree that the original ESRS will likely become a gold standard (but I still hope ESRS E4, the “biodiversity standard” will not be weakened too much). The EU Taxonomy is already used by some of our clients as a way to define “green” activities even when they are not subject to any obligations. So it is likely the ESRS will follow a similar path. But I feel like Dr Michael Burgass is way too optimistic.

Biodiversify ’s clients may be acting for biodiversity because they understand the risks & opportunities but:

- the vast majority of companies (the CSRD was supposed to cover 6000+) are not their clients and are not going to act if not forced to do so by regulations

- biodiversity risks are mostly linked to common or public goods: no single company can reduce those risks alone. For instance the flood regulation ecosystem service requires action at the watershed level to restore wetlands and reduce risk of damages from flood at a company’s plants. That requires coordination from many companies and stakeholders within that watershed. So even if they understand the risks, companies may have very limited incentives to bear all the costs and reap almost no reward (if other stakeholders do not also act, the action of one company will not increase flood regulation by ecosystems).

And, having been involved in the drafting of ESRS E4, I think it is important to clarify that:

- it was based on a very robust process involving very competent people, many rounds of consultations, and the use of best available indicators

- we need to and can be ambitious: we cannot just limit ourselves to what companies already measured in 2018 when setting the requirements of what they should report in 2025 and for years to come.

The EFRAG provided many clarifications in FAQ and guidance documents associated to the ESRS.

And with several years between the initial drafts circulated and the actual implementation of the regulation, there was enough time to develop guidance and detailed approaches, and that is what has happened and is happening.

I think the balance between ambition and conservatism in terms of what was requested from company erred rather on the cautious side. Yes, the ESRS E4’s indicators are relatively ambitious, but they are manageable.

So I believe “environmental actors” (those acting in favour of the environment) should not repeat the bad-faith criticisms of the CSRD of regressive business lobbies.

Overall, I am quite concerned that the Omnibus is a mistake and will weaken actions for biodiversity (let's remember that it may however be significantly altered through negotiations with the Parliement and Council).

I may be wrong (and hope so) and it may turn out to be an opportunity if ESRS E4 is not weakened too much and rather benefit from “good” simplications.

So let’s hope that indeed “the genie is out the bottle now though with this topic and we are going to see continued momentum and acceleration regardless of what corporate reporting requires”.

And meanwhile, let's continue to push for ambitious biodiversity actions because we depend on biodiversity and because it is the right thing to do.

Disclaimer: all views are mine and do not represent any institution or initiative's.

Access previous issues of the Nature Intelligence Newsletter:

Case studies and examples

#01 - Impacts on ecosystem integrity of a listed equity index assessed for the first time - STOXX600

#08 - Getting inspired: 3 front-runners who assessed their biodiversity impacts at the corporate level

#09 - Ecosystem condition: direct measurement and assessment of regulatory offsets

Ecosystem condition definition and metrics

#02 - All you ever wanted to know about the MSA

#03 - Ecosystem condition: the indicator to watch for corporate biodiversity performance

Biodiversity measurement tools

#04 – Differences between the corporate biodiversity metrics