The Omnibus simplification packages
Summary
2. Omnibus II - Simplifying investment
The second package concerns InvestEU and the European Fund for Strategic Investments. It was presented on 14 May 2025 and aimed to facilitate the mobilisation of public and private investment by simplifying reporting rules and increasing the efficiency of European financial instruments.
The Commission estimated administrative savings of around €350 million, of which €324 million would be a one-off saving, and the potential to mobilise around €50 billion in additional public and private investment. The package is significant for competitiveness as it addresses the key issue of access to finance, which is particularly important for SMEs, mid-cap companies and innovative enterprises.
Specifically, the regulation has increased the EU’s InvestEU guarantee by €2.9 billion, raising it from €26.2 billion to €29.1 billion. This increased capacity should make it possible to mobilise at least €50 billion in additional public and private investment, in support of European priorities relating to competitiveness, the Clean Industrial Deal, industrial policy and defence investment.
The new regulation also makes it possible to make better use of resources and guarantees still available from previous European investment instruments, preventing them from remaining unused in programmes that are now obsolete. In particular, the measure concerns the former European Fund for Strategic Investments (EFSI), also known as the ‘Juncker Plan’; the CEF Debt Instrument, used to finance infrastructure in the transport, energy and digital sectors; and the InnovFin Debt Facility, linked to Horizon 2020 and designed to support research, innovation and innovative businesses. Thanks to the simplification introduced by Omnibus II, these residual capacities can be combined more easily with InvestEU, putting resources back into circulation that can help finance new projects.
Another significant aspect concerns the simplification of reporting obligations. The regulation reduces the frequency and scope of the information required from implementing partners, providing in particular for a shift from half-yearly to annual reporting. Indeed, at an operational level, the entry into force of the regulation triggered, during 2026, the updating of guarantee agreements and the adaptation of reporting systems by the implementing partners. The latter are the financial intermediaries responsible for making the instruments backed by the EU guarantee effectively available. As you may recall, the Commission does not finance businesses directly, but entrusts operational management to entities such as the EIB Group, national promotional banks and other selected intermediaries. These use the European guarantee to offer loans, guarantees or other financial products to eligible businesses, public bodies and investment promoters. In Italy, for example, a key implementing partner is Cassa Depositi e Prestiti (CDP), which has signed an InvestEU guarantee agreement with the European Commission to mobilise new funding in support of investments in research and development, the green transition, and social and sustainable infrastructure. The simplification of reporting requirements provided for under Omnibus II therefore mainly concerns banking institutions, reducing the administrative burden involved in managing InvestEU instruments.
These developments may, however, translate into tangible benefits for SMEs. In particular, the reduction in bureaucratic burdens for transactions under €300,000 may encourage local credit institutions to expand their offering of microcredit and small-scale loans, whilst at the same time reducing processing times for businesses. This makes it possible to streamline guidance services and to direct businesses more effectively towards financial intermediaries authorised to provide InvestEU guarantees.
For further information: here
3. Omnibus III - Common Agricultural Policy
The third Omnibus package is dedicated to simplifying the Common Agricultural Policy — CAP 2023–2027. The proposal was presented by the European Commission on 14 May 2025 and was approved particularly swiftly: the European Parliament and the Council reached a provisional agreement on 10 November 2025, the Parliament adopted its position on 16 December 2025, and the Council gave its final approval on 18 December 2025. The final act is Regulation (EU) 2025/2649, signed on 19 December 2025, published in the Official Journal of the European Union on 31 December 2025 and which entered into force on 1 January 2026.
According to European Commission estimates, the package could generate annual administrative savings of around €1.58 billion for farmers and €210 million for national administrations. The aim is to reduce administrative complexity, repetitive checks and reporting obligations, making it easier to implement the CAP without altering its overall framework.
Omnibus III amends the CAP currently in force, introducing targeted simplifications for farmers, beneficiaries and national administrations. The regulation amends two key pieces of legislation under the 2023–2027 CAP: Regulation (EU) 2021/2115 on CAP strategic plans, and Regulation (EU) 2021/2116 on financing, management and monitoring. This is a targeted intervention in the agricultural policy already in operation, prompted in part by pressure from the agricultural sector in recent years, where the complexity of European compliance requirements has been identified as one of the main sources of difficulty for farms.
A first area concerns cross-compliance, that is, the set of minimum rules that farmers must comply with in order to receive CAP payments. These include the BCAA/GAEC, or good agronomic and environmental conditions of the land. The new regulation introduces greater flexibility, particularly for certain categories of farms. For parts of a farm that are already certified organic or in the process of converting to organic farming, farmers are automatically deemed to comply with certain environmental standards under the CAP. The aim is to avoid duplication between checks relating to organic certification and those required under the CAP.
Still on the subject of cross-compliance, the regulation introduces simplifications linked to farm size. Farms of up to 10 hectares are exempt from cross-compliance checks and the associated penalties. Furthermore, farms of up to 30 hectares are not subject to checks and penalties relating to BCAA 7, which concerns crop rotation. The obligation for Member States to review cross-compliance control systems annually is also removed, thereby reducing the administrative burden on national authorities.
Another change concerns the status of arable land. The regulation stipulates that land classified as arable on 1 January 2026 may retain that status even if it is not ploughed, tilled or reseeded. The measure aims to prevent agricultural interventions driven by administrative requirements rather than productive or environmental needs.
The package also strengthens support for small farmers. The simplified annual payment for small farms can amount to up to 3,000 euros, whilst a one-off grant of up to 75,000 euros is introduced to support the business development of small farms. The rationale is to ensure a more proportionate relationship between the amount of aid and the administrative requirements, preventing smaller farms from having to bear the same bureaucratic burden as larger ones.
A further section concerns CAP payments. At national level, AGEA (the Agency for Agricultural Payments) has implemented the provisions of the new regulation through Circular No. 9304 of 4 February 2026, providing the first operational guidelines on the measures that are directly applicable. These include the standardisation of CAP advance payments: from 2026 onwards, paying agencies must disburse advances between 16 October and 30 November, applying as a general rule the new percentages set out in the regulation, namely 70% for direct payments and 85% for rural development measures. It will therefore no longer be necessary to wait for specific European regulations or further AGEA circulars to authorise such advances.
Regarding checks, the principle of the ‘single check’ is being strengthened: when a beneficiary is selected for an on-the-spot check, the authorities must, as far as possible, avoid carrying out further physical checks in the same year. The measure does not eliminate checks, but aims to make them more coordinated and less repetitive.
This simplification is accompanied by greater use of digital tools. Member States may avoid on-farm visits where requirements can be verified through the Area Monitoring System, which is based on satellite imagery and digital tools. Furthermore, georeferenced photographs taken by the beneficiary or the CAA and linked to the graphical cultivation plan may be used as evidence for the purposes of aid disbursement. In this way, physical checks can be limited to cases where doubts or inconsistencies arise that cannot be resolved using digital tools.
For national administrations, the regulation simplifies the management of CAP strategic plans. Changes deemed strategic continue to require the approval of the European Commission, whilst for less significant changes a more streamlined process, based on notification, is provided for. This should enable Member States to adapt their plans more quickly to operational needs, crises or implementation difficulties.
The regulation also abolishes the annual performance clearance, i.e. an annual review of performance linked to the implementation of the CAP. The removal of this step reduces reporting and control obligations for Member States, whilst maintaining the overall framework for monitoring agricultural policy.
The package also introduces greater flexibility for crisis management. Member States may provide for crisis payments to active farmers affected by natural disasters, adverse climatic events or catastrophic events, with the aim of ensuring the continuity of agricultural activity and supporting farms during times of greatest difficulty.
Another area concerns rural development measures funded by the EAFRD. The regulation expands the use of simplified cost options, allowing, for certain categories of expenditure, the use of flat-rate or standardised calculation methods already provided for in other European funds. This option applies, amongst other things, to indirect costs, staff costs and other eligible costs up to 40 per cent of staff costs. The aim is to simplify investment reporting and reduce the administrative burden on beneficiaries and public authorities.
A specific new provision concerns the livestock sector. As an exception to the general principle that the purchase of animals is ineligible, the regulation allows for the financing of the purchase of pure-bred cattle, sheep and goats of high genetic value intended for breeding. The measure is aimed at improving the quality and productivity of livestock herds or at preserving rare or local breeds. Outside these specific objectives, the purchase of animals remains excluded from eligible expenditure.
Finally, the AGEA circular outlines the new procedures for assessing the quality of CAP control systems. From 2026, the assessment of SIPA, GSA and AMS will be carried out in a unified and integrated manner at national level, replacing the previous separate assessments. AGEA will also coordinate a procedure for the early identification of critical issues, with the aim of preventing financial corrections and facilitating the timely adoption of corrective measures prior to the Commission’s audits.
For further information: here
4. Omnibus IV - Small mid-caps, digitalisation and common specifications
The fourth Omnibus package, presented by the European Commission on 21 May 2025, concerns the simplification of the single market, with a particular focus on small mid-caps, the digitalisation of product legislation, the harmonisation of common specifications and the deferral of due diligence obligations in the battery sector. The package comprises five proposals: an amendment to the Batteries Regulation, two proposals on small mid-caps and two proposals on digitalisation and common specifications in product legislation. The ‘batteries’ component has already been definitively adopted, whilst the European Parliament and the Council reached a provisional agreement on the other four proposals on 9 June 2026; the process is therefore not yet complete and trilogues have not yet begun.
According to the European Commission’s estimates, the measures in Omnibus IV should enable European businesses to achieve administrative savings of around €400 million per year. These savings stem mainly from the extension of certain simplifications to small and mid-caps, the reduction of paperwork requirements in product legislation, the digitisation of declarations and instructions for use, simpler ways of demonstrating product compliance, and a more phased implementation of due diligence obligations in the battery sector.
The Omnibus IV package therefore takes an integrated approach to four areas: batteries, small and mid-caps, the digitisation of product legislation, and common specifications. The ‘batteries’ component is the only part of the package that has already become law. Regulation (EU) 2025/1561, which entered into force on 31 July 2025, amends Regulation (EU) 2023/1542 on batteries and waste batteries, postponing the application of due diligence obligations along the supply chain by two years. In practical terms, the obligations that were due to apply from 18 August 2025 will now apply from 18 August 2027.
The 2023 Batteries Regulation had introduced obligations aimed at ensuring that certain raw materials used in batteries – in particular cobalt, lithium, nickel and natural graphite – were sourced responsibly. The companies concerned are required to adopt due diligence policies, assess social and environmental risks in the supply chain, put in place measures to prevent or mitigate them, and have the system verified by third-party bodies. The postponement therefore aims to give battery manufacturers, importers and exporters more time to prepare for complex rules, which require the mapping and monitoring of supply chains for critical raw materials.
The second component concerns small mid-caps, i.e. companies that have exceeded the SME threshold but cannot yet be considered large enterprises. Under the European system, the definition of an SME normally applies up to 250 employees. When a company exceeds this threshold, even by a small margin, it may suddenly lose the simplifications, concessions and proportionate obligations provided for SMEs, even though it does not yet have the organisational, administrative and financial capacity of a large company. This is the so-called ‘step effect’, which can turn growth in size into a regulatory burden. To address this issue, Omnibus IV introduces an intermediate category. Under the provisional agreement reached by the European Parliament and the Council, ‘small mid-caps’ are defined as companies with fewer than 1,000 employees and an annual turnover of up to 200 million euros, or a balance sheet total of up to 172 million euros. In practical terms, this means recognising that a company with 300, 500 or 800 employees may have different needs from a multinational, particularly when it comes to dealing with administrative obligations, documentation requirements, reporting or complex technical procedures. The measure aims to support the scale-up of European companies, ensuring that exceeding the SME threshold does not become a disincentive to growth.
The third strand concerns the digitisation of product legislation. Many European product regulations still require documents, instructions, declarations or notifications in paper format, resulting in costs and duplication of effort for businesses and public authorities. Omnibus IV introduces the ‘digital by default’ principle, i.e. the possibility of using digital format as the standard method for fulfilling certain obligations. Among the most significant examples is the EU declaration of conformity – the document in which the manufacturer declares that a product complies with the applicable European standards. Thanks to these simplifications, this document can be managed more easily in digital format. The same applies to certain exchanges between businesses and the relevant national authorities, as well as to instructions for use, which may be provided in digital format rather than always on paper. However, according to the Commission’s proposal, where the information concerns essential safety aspects and there is a risk of serious harm, a paper version must also remain available. In other words, the package aims to reduce paper use where it is not necessary, without compromising access to information that is essential for the safe use of a product.
The fourth element concerns common specifications. Many European product standards set out general requirements for safety, quality or performance, whilst the technical details are often defined through harmonised standards drawn up by European standardisation bodies. When a company complies with these standards, it can more easily demonstrate that its product complies with EU legislation. The problem arises when technical standards are not yet available, are delayed or do not adequately cover all the requirements set out in the legislation. In such cases, businesses may find themselves in a situation of uncertainty: the law requires them to demonstrate product compliance, but there is no clear technical standard to follow.
This is why Omnibus IV introduces common specifications as a fallback mechanism. These are technical guidelines adopted by the European Commission that companies can use to demonstrate product conformity when harmonised standards are lacking or insufficient. The provisional agreement makes it clear, however, that they must not become the norm: the main system remains that of harmonised standards, whilst common specifications serve as an alternative solution in exceptional cases where standards are unavailable or do not adequately meet the requirements of the legislation.
For further information: here
5. Omnibus V - Defence Readiness
The European Commission presented the Defence Readiness Omnibus on 17 June 2025, as the fifth simplification package aimed at strengthening European industrial and technological readiness in the defence sector. The Council adopted its position on 26 November 2025, and the European Parliament and the Council reached a provisional agreement on 10 June 2026. The Parliament and the Council reached a provisional agreement on 10 June 2026. The legislative process is now moving towards its natural conclusion with the standard procedures for formal adoption by the two institutions.
The package forms part of the White Paper on European Defence Readiness 2030 and the Readiness 2030/ReArm Europe plan, through which the EU intends to facilitate up to €800 billion in additional defence investment over the next four years. The Defence Readiness Omnibus does not in itself generate these resources, but aims to remove the regulatory and administrative barriers that can slow down investment, production, procurement, authorisations and cross-border cooperation in the defence sector. According to the Commission’s Staff Working Document, the simplifications set out in the package could generate total economic benefits of between €42.5 and €51.3 billion over the period 2026–2036.
The Defence Readiness Omnibus addresses a set of rules and procedures that directly affect the EU’s ability to accelerate investment, production, procurement and industrial cooperation in the defence sector.
The package comprises two proposals for regulations, a proposal for a directive and a number of draft delegated acts. In practical terms, it amends existing rules to make certain procedures – currently considered too slow – faster and less burdensome: authorisations for new industrial projects, public procurement in the defence sector, transfers of military products between Member States, access to European funds, and the application of certain environmental and chemical regulations to projects relevant to defence readiness.
A first strand concerns authorisations for projects linked to defence readiness. These include, for example, new production facilities, expansions of industrial sites, infrastructure or activities necessary to increase production capacity in the defence sector. The provisional agreement introduces a harmonised framework to speed up the granting of permits, setting a maximum duration of 102 working days for the procedure. If the competent authority fails to reach a decision within the prescribed time limit, the application may be deemed to have been tacitly approved. However, this rule is not absolute: Member States may provide for exceptions, particularly where there are serious risks to human health or national security. The aim is to reduce administrative delays without removing essential safeguards.
A second strand concerns public procurement in the defence sector. The current rules are often regarded as complex and ill-suited to a context in which Member States need to replenish stocks, rapidly acquire capabilities already available on the market and cooperate with one another. The Omnibus Directive therefore introduces greater flexibility: it raises certain thresholds set out in the Defence Procurement Directive, so as to focus the most onerous obligations on the most significant contracts; it facilitates occasional joint procurement between Member States; it simplifies the use of framework agreements; and it introduces a ‘de minimis’ rule for certain contractual amendments, preventing minor changes from triggering disproportionate procedures.
A third element concerns intra-EU transfers of defence products. At present, the transfer of military components, systems or products between Member States may require authorisations and administrative procedures that slow down production and industrial cooperation, particularly when a project involves companies based in several European countries. The agreement introduces two new mandatory general licences: one for transfers between certified suppliers and recipients, and one for transfers within the framework of intra-EU industrial partnerships. The aim is to facilitate the movement of defence products and components within the European market, reducing delays and fragmentation.
The package also addresses the European Defence Fund (EDF), the instrument through which the EU funds collaborative research and development projects in the defence sector, involving companies, research centres and Member States. The Omnibus simplifies application and project management procedures, aims to reduce the administrative burden on participants and makes the implementation of the Fund more predictable. The provisional agreement also strengthens incentives for SME participation, providing for an increase in the funding bonus for projects involving small and medium-sized enterprises. It also clarifies the delicate balance between the right of co-funding Member States to access project results and the protection of participating companies’ intellectual property.
Another area concerns the application of environmental and chemicals legislation to defence-related activities. The package clarifies how certain derogations already provided for under EU law may be used for defence readiness purposes, whilst maintaining a high level of protection for human health and the environment. In particular, it clarifies certain aspects of chemicals legislation, including cases where defence requirements may necessitate flexibility in the use of critical substances. The political challenge is to balance two objectives: to prevent general rules from slowing down projects essential to security and, at the same time, to ensure that simplification does not lead to a general lowering of environmental and health standards.
Finally, the package addresses access to finance. The Commission has proposed to clarify the eligibility of defence investments under European instruments such as InvestEU and to provide greater certainty for investors, including with regard to sustainable finance. The message is that defence, whilst maintaining specific characteristics and restrictions linked to certain internationally prohibited weapons, should not be automatically excluded from funding channels when it contributes to European security and resilience.
For further information: here
6. Omnibus VI - Chemicals
The sixth Omnibus package, presented by the European Commission on 8 July 2025, concerns the simplification of European chemicals legislation. The objective is to reduce compliance costs and administrative burdens for companies within the chemical supply chain, whilst maintaining a high level of protection for human health, consumers, and the environment. The package includes a "stop-the-clock" component, already adopted as Regulation (EU) 2025/2439, and a substantive proposed regulation, COM(2025) 531, regarding CLP, cosmetics, and fertilising products. The European Parliament and the Council reached a provisional agreement on the latter proposal on 17 June 2026, though the legislative process has not yet formally concluded.
According to the European Commission, Omnibus VI is expected to generate annual savings for the industry of at least €363 million. This is a highly significant package for a strategic, heavily regulated sector that lies at the heart of many European industrial supply chains. The savings will primarily stem from simplified labelling rules, the broader use of digital tools, better coordination of application dates, and clearer procedures for chemicals, cosmetics, and fertilisers.
Omnibus VI addresses three main areas of European chemicals legislation: the classification, labelling, and packaging of chemical substances and mixtures; cosmetic products; and fertilising products.
The first component of the package concerns the CLP (Classification, Labelling and Packaging) regulation. The underlying CLP regulation, Regulation (EC) No 1272/2008, sets out how chemical substances and mixtures must be classified based on their hazards, labelled, and packaged before being placed on the EU market. This regulation had been amended by Regulation (EU) 2024/2865, which introduced new requirements for labelling, advertising, distance selling, and digital information.
Through Omnibus VI, the legislator first intervened via Regulation (EU) 2025/2439, adopted on 26 November 2025 and published in the Official Journal on 3 December 2025. This is the "stop-the-clock" component, designed to push back certain application dates and better coordinate the transitional provisions of the CLP revision. Specifically, some deadlines set for 1 July 2026 and 1 January 2027 have been deferred to 1 January 2028, giving businesses more time to comply with the new obligations.
The second component is the proposed regulation COM(2025) 531, presented by the Commission on 8 July 2025, which amends three sectoral acts: the CLP regulation, Regulation (EC) No 1223/2009 on cosmetic products, and Regulation (EU) 2019/1009 on fertilising products. This section contains substantial simplifications regarding requirements, procedures, labelling, and information obligations. The European Parliament and the Council reached a provisional agreement on this proposal on 17 June 2026.
Regarding the CLP, the provisional agreement aims to build more flexibility into certain labelling obligations introduced by the 2024 revision. The CLP dictates how hazard information, such as pictograms, signal words, hazard statements, and precautionary statements, must be displayed on chemical products. Omnibus VI maintains the goal of ensuring clear and legible labels but softens the rigid approach of the previous revision, particularly in business-to-business (B2B) relations. In B2B transactions, readability criteria become less prescriptive regarding format, fonts, and spacing; however, for products intended for the public, more stringent safeguards remain to ensure essential safety information is easily readable.
The agreement also introduces greater flexibility for small packaging. In some instances, the available space on the label does not allow all the required information to be displayed legibly. Under Omnibus VI, companies will be able to more easily use alternative solutions, such as fold-out labels, information on the outer packaging, or digital tools, provided that essential information remains accessible. The aim is to prevent obligations designed for standard packaging from becoming disproportionate for smaller products.
Another change concerns the timeframes for updating labels. When a substance or mixture's classification changes and the product is deemed more hazardous than previously indicated, the company must update the label. The agreement grants a few additional months to carry out this update, allowing a more realistic timeframe for modifying packaging, labels, IT systems, and existing stock. This does not remove the obligation to update hazard information but makes the transition more manageable.
The package further confirms a greater openness to digital tools. Certain information can be provided more easily in a digital format, for example, through electronic channels or links accessible on the product. Nevertheless, essential safety information must remain immediately available when needed. The rationale is to cut down on paper and increase flexibility without compromising user safety.
The second block concerns cosmetic products. The cosmetics regulation governs the safety and marketing of products like creams, perfumes, make-up, shampoos, and other personal care items. Omnibus VI primarily intervenes on the transitional periods for phasing out substances classified as CMR (carcinogenic, mutagenic, or toxic for reproduction). Instead of enforcing a single uniform deadline, the agreement sets timeframes that are more proportionate to the risk level and calls on the Commission to publish guidance on the definitions and use of safer alternative substances.
Also, regarding cosmetics, the agreement maintains specific safeguards for nanomaterials, which are used in certain products to achieve effects or performance. Due to their unique characteristics, nanomaterials may require specialised assessments. The compromise therefore confirms the obligation of an extensive prior notification before placing cosmetics containing them on the market, ensuring adequate preventive checks to protect health and the environment.
The third block relates to fertilising products. The amendments aim to simplify the authorisation of materials that can be used in CE-marked fertilisers. The agreement asks the Commission to modernise the registration rules for certain components, such as microorganisms, animal by-products, polymers, and other materials, that are currently difficult to register as they do not clearly fit into existing categories.
Crucially, the package does not strip away safety safeguards. The agreement maintains the REACH registration obligation for certain substances of very high concern subject to harmonised classification.
With the provisional agreement of 17 June 2026, the European Parliament and the Council also scheduled a further postponement to 1 January 2030 to align the application of the amendments relating to the three relevant regulations: CLP, cosmetics, and fertilisers.
For more information: here
7. Omnibus VII - Digital
The seventh Omnibus package, presented by the European Commission on 19 November 2025, focuses on simplifying European digital legislation. The package addresses a regulatory framework that is now vast, encompassing rules on data, cybersecurity, artificial intelligence, digital privacy, electronic identity, and corporate reporting obligations. The aim is to cut down on overlaps, duplication, and application uncertainties, whilst maintaining fundamental safeguards for citizens, consumers, and businesses. Omnibus VII includes two main legislative proposals: proposal COM(2025) 836, regarding the simplification of certain provisions of the AI Act, and proposal COM(2025) 837, which takes a transversal approach across the broader European digital regulatory framework. The artificial intelligence component is the most advanced: the European Parliament and the Council reached a provisional agreement on 7 May 2026, and the Council gave its final green light on 29 June 2026. Proposal COM(2025) 837 is following the ordinary legislative procedure and has yet to be negotiated.
According to the European Commission, the digital package should help slash administrative costs by up to €5 billion by 2029. The expected savings stem from streamlining the implementation of the AI Act, reorganising data rules, reducing duplication in cybersecurity incident reporting obligations, rationalising cookie rules, and providing greater legal certainty for businesses and public administrations. The package also ties into the Commission’s broader simplification strategy, which aims to reduce recurring administrative costs over the 2024–2029 mandate.
Omnibus VII intervenes in the European "digital rulebook" to make the application of EU digital rules more straightforward and consistent.
The first proposal, COM(2025) 836, concerns the AI Act, the European regulation on artificial intelligence built upon a risk-based approach. Omnibus VII does not question the underlying structure of the AI Act but tweaks some of its practical aspects to prevent businesses and authorities from having to comply with complex obligations before the relevant technical standards, guidelines, and support tools are actually available. Specifically, the rules on high-risk AI systems have been delayed: the new application date is set for 2 December 2027 for standalone high-risk systems, and 2 August 2028 for high-risk systems embedded in products regulated by sectoral legislation (such as machinery, medical devices, or toys).
The logic behind the delay is practical: the AI Act's most complex obligations should only kick in when the technical reference framework is sufficiently clear. The Commission will also be required to provide guidance to help economic operators meet the requirements for high-risk systems, keeping compliance burdens to an absolute minimum.
The agreement on the AI Act also introduces some substantive changes. A new ban has been inserted regarding the generation of non-consensual sexual or intimate content, as well as child sexual abuse material (CSAM), via AI systems. Furthermore, the timeframe granted to providers to implement transparency solutions for artificially generated content has been halved from six to three months, with the new deadline set for 2 December 2026. The package also pushes back the deadline for establishing national regulatory sandboxes, controlled environments where businesses and authorities can test innovative AI solutions under supervision, to 2 August 2027.
Another point addresses the supervision of general-purpose AI models. The agreement clarifies the remits of the AI Office (the European body tasked with coordinating the implementation of the AI Act), particularly when the same provider develops both the AI model and the system utilising it. However, exceptions are carved out where national authorities remain competent, for instance, in sensitive areas like law enforcement, border management, judicial authorities, and financial institutions.
Omnibus VII also deals with the overlap between the AI Act and sectoral regulations. Certain products, such as machinery, medical devices, toys, lifts, or recreational craft, are already governed by European technical rules. The package therefore seeks to prevent companies from having to comply with two overlapping sets of requirements for the same risk. A specific workaround is provided for the machinery regulation: AI-related requirements can be integrated via delegated acts within the sectoral regulatory framework, rather than applying the AI Act's provisions redundantly.
The second proposal, COM(2025) 837, is the Digital Omnibus Regulation. This section transversally affects a large swathe of European digital legislation, aiming to reduce overlap, duplication, and legal uncertainty for businesses and public bodies. Unlike the AI Act proposal, this component has not yet completed its legislative journey.
A primary area of focus is the reorganisation of the European data regulatory framework. Over recent years, the EU has passed several legislative acts on data access, sharing, reuse, and circulation, including the Data Act, the Data Governance Act, the Open Data Directive, and the regulation on the free flow of non-personal data. The proposal aims to consolidate parts of this framework, rolling provisions currently found in other acts into a restructured Data Act. This should make it easier for businesses to understand exactly which rules apply to data access, sharing, and usage.
Remaining on the topic of data, the proposal tweaks the Data Act’s rules regarding switching cloud service providers. The Data Act is designed to make it easier to move from one cloud provider to another, preventing technological or contractual lock-in. However, some technical obligations can be disproportionate for smaller operators. To resolve this, the proposal introduces targeted exemptions for small businesses, upholding the principle of data portability but with more proportionate compliance requirements.
The proposal also provides practical tools to reduce uncertainty in data-related contracts. Notably, the Commission will provide contractual templates for data access and use, as well as standard contractual clauses for cloud contracts. For a business, this means being able to work from standardised European templates rather than having to negotiate complex clauses on data access, usage, provider switching, liability, and interoperability from scratch every single time.
Another intervention involves the P2B (Platform-to-Business) Regulation, which governs the relationships between online platforms and their business users. The regulation was introduced to increase transparency regarding contractual terms, ranking criteria, and the grounds on which platforms can suspend or restrict access for business users. Proposal COM(2025) 837 slates it for repeal, as much of its content has since been superseded or absorbed by the Digital Services Act, which contains broader and more up-to-date obligations for online platforms.
The proposal then tackles the GDPR (General Data Protection Regulation). This is a particularly delicate issue. The Commission proposes clarifying the processing of pseudonymised data, data that does not directly identify a person but could be linked to an individual if additional information were available. Under the proposal, such data would not be classed as personal data for an entity that does not reasonably possess the means to re-identify the person. The proposal also outlines that, under certain conditions, businesses may rely on "legitimate interest" to use personal data in the training or operation of AI systems and models. This is one of the most politically sensitive points, as it strikes at the balance between innovation, personal data protection, and legal certainty for businesses.
Another area concerns cookies and tracking technologies. Today, many users face a barrage of consent requests that are often repetitive and confusing. Omnibus VII aims to alleviate this "consent fatigue" by shifting some cookie rules from the ePrivacy Directive into the GDPR and expanding the scenarios where consent is not required. The proposal also includes solutions such as saving preferences at the browser or system level and simpler consent mechanisms, whilst maintaining consent as the fundamental gateway for accessing information on a user's device.
Finally, the package touches on cybersecurity, specifically the streamlining of incident reporting obligations. Over the last few years, several European legislative acts have introduced obligations to report incidents, breaches, or operational disruptions to competent authorities. These include the NIS2 Directive, the DORA regulation on digital operational resilience in the financial sector, the CER Directive on the resilience of critical entities, the GDPR, the eIDAS regulation, and the Cyber Resilience Act. In some cases, a single event can fall under multiple legal regimes, forcing a company to report the incident several times over, with differing deadlines, formats, and recipients.
To cut through this fragmentation, proposal COM(2025) 837 introduces a "single entry point" for reporting cybersecurity incidents and data breaches. In practice, a company should be able to submit its notification through a single European portal rather than sending separate alerts to multiple authorities. This single-entry point would be built and run by ENISA, the European Union Agency for Cybersecurity. ENISA would act as the central technical hub, collecting notifications and distributing them to the relevant authorities, without usurping their supervisory or decision-making roles.
The proposal, however, does not scrap substantive cybersecurity obligations. Companies subject to NIS2, DORA, CER, GDPR, eIDAS, or the Cyber Resilience Act will still be required to prevent and manage risks, adopt appropriate technical and organisational measures, and report significant incidents. The simplification is fundamentally about “how” to report, not “whether” to report.
For more information: here
8. Omnibus VIII - Environmental Legislation
The eighth Omnibus package, tabled by the European Commission on 10 December 2025, relates to the simplification of European environmental legislation. The package addresses industrial emissions, the circular economy, environmental assessments, extended producer responsibility, and geospatial data. Its goal is to reduce administrative burdens and speed up certain procedures without watering down environmental protection targets. Omnibus VIII is made up of six legislative proposals: one on environmental reporting and batteries; two on authorised representative obligations in extended producer responsibility schemes; one on accelerating environmental assessments; one on the INSPIRE Directive; and a final proposal covering waste, industrial emissions, livestock farming, and medium combustion plants.
According to the European Commission, the package is expected to generate approximately €1 billion in total savings, of which €890 million will be annual administrative savings. For businesses, the intervention is especially relevant when it comes to authorisations, environmental procedures, reporting, and the obligations tied to extended producer responsibility schemes. The aim is to cut out duplication, dial back disproportionate compliance tasks, and make better use of data already held by public bodies, all without lowering the bar for health and environmental protection.
Omnibus VIII cuts across various segments of European environmental law to streamline reporting, authorisations, inspections, and organisational obligations for businesses.
The first proposal is COM(2025) 981, which amends Regulation (EU) 2023/1542 on batteries and waste batteries, and Regulation (EU) 2024/1244 on the Industrial Emissions Portal. The Industrial Emissions Portal is a European database that gathers and publishes data on the emissions and environmental performance of specific industrial installations and activities. It doesn't apply to every business, but only to facilities and activities exceeding certain thresholds or belonging to sectors deemed environmentally significant, such as large industrial plants, power stations, refineries, chemical plants, waste treatment facilities, some mining activities, large intensive livestock farms, and, in some cases, aquaculture.
The proposal looks to scale back direct reporting for certain categories of operators. In particular, the Commission proposes exempting livestock and aquaculture operators from the obligation to report data on water, energy, and material usage. Member States could also exempt these operators from having to submit data on off-site waste transfers, the release of pollutants into wastewater, production volumes, and operating hours, provided that this information can be sourced or estimated from other reliable databases. Essentially, if the public authority already has equivalent data or can obtain it via alternative routes, the operator shouldn't have to submit the exact same information twice.
Alongside the Industrial Emissions Portal changes, proposal COM(2025) 981 makes targeted tweaks to the batteries regulation. These are distinct from the "stop-the-clock" component already adopted in Omnibus IV regarding battery due diligence obligations. Here, the Commission proposes technical adjustments to clarify certain compliance obligations and ease burdens. These modifications include clarifying the definition of "producer" in distance contracts (crucial for online and cross-border sales), introducing a definition for "substances of very high concern" (SVHC) regarding information obligations, and granting some flexibility for battery packs intended for light transport, such as e-bikes and e-scooters.
The second proposal, COM(2025) 982, presented on 10 December 2025, is a proposed regulation suspending the application of rules on appointing an authorised representative for extended producer responsibility (EPR) concerning batteries, waste batteries, packaging, and packaging waste. EPR is the principle whereby a producer remains responsible, financially or organisationally, for managing a product once it becomes waste. Essentially, whoever places certain products on the market must chip in for the costs of collecting, treating, recycling, and properly managing the resulting waste.
Proposal COM(2025) 982 suspends until 1 January 2035 the provisions that make it mandatory to appoint an authorised representative for EPR in the sectors covered by the Batteries Regulation and the Packaging and Packaging Waste Regulation (PPWR). The suspension specifically applies to producers established in the EU who sell batteries or packaging in Member States other than the one in which they are established.
An authorised representative is a local point of contact designated by a producer in a Member State where they sell goods but have no physical establishment. For a company trading across multiple EU countries, the current rules can mean having to appoint different representatives in several Member States, racking up administrative and organisational costs. The proposal therefore seeks to prevent companies already established in the Union from facing duplicated burdens in every single national market they operate in.
Waste, WEEE, and Single-Use Plastics
The third proposal, COM(2025) 983, is a proposed directive suspending the rules on appointing authorised representatives for EPR concerning waste, waste electrical and electronic equipment (WEEE), and waste from single-use plastic products. The co-legislators have not yet adopted their negotiating stance on this proposal.
This proposal impacts three pieces of legislation: the Waste Framework Directive; the WEEE Directive (covering waste from computers, phones, household appliances, etc.); and the Single-Use Plastics (SUP) Directive. As above, the Commission proposes suspending until 1 January 2035 the requirement to appoint authorised representatives for EPR for producers established in the EU who sell into other Member States. Pausing these rules until 2035 should prevent duplicated compliance tasks and allow time to evaluate more harmonised solutions.
The fourth proposal, COM(2025) 984, aims to speed up environmental assessments. It focuses heavily on coordinating the various assessment tools mandated by European law, including Environmental Impact Assessments (EIA) for projects, Strategic Environmental Assessments (SEA) for plans and programmes, assessments under the Habitats and Birds Directives, and elements of the Water Framework Directive. The goal is to make environmental assessments more integrated, predictable, and less fragmented, preventing overlap between procedures that frequently look at very similar issues.
In practical terms, the proposal seeks to bolster the 'one-stop-shop' principle and administrative coordination. For project developers, this should mean greater clarity on which authority is in charge, what information is required, the necessary procedural steps, and the timeframes involved. For public bodies, it aims to streamline the interplay between different assessments, reducing the likelihood of repeated requests, disjointed feedback, or endlessly drawn-out procedures.
The fifth proposal, COM(2025) 985, amends the INSPIRE Directive, which underpins the European spatial data infrastructure. INSPIRE was adopted to make spatial (geospatial) data held by public authorities more accessible and interoperable, particularly data relevant to environmental policy (e.g., land use, water networks, protected areas, infrastructure).
Over the years, the European public data framework has moved on considerably, with the introduction of the Open Data Directive, the regulation on high-value datasets, and the Data Governance Act. The Commission therefore believes it is time to align INSPIRE with this newer framework. It proposes that spatial data should increasingly be accessed via the European public data portal (data.europa.eu) rather than through disjointed systems, and it scraps the Commission's obligation to run the INSPIRE geoportal as a standalone piece of infrastructure. It also trims down specific reporting obligations under INSPIRE that are now covered by newer rules.
The sixth proposal, COM(2025) 986, is the most wide-ranging, tackling the Waste Framework Directive, the Industrial Emissions Directive (IED), livestock farming rules, and the medium combustion plants directive.
Regarding waste, it proposes repealing the SCIP database (the European system tracking substances of very high concern in articles). The Commission argues that some of these reporting duties have proven exceptionally heavy and disproportionate to the actual utility of the data gathered. For the Industrial Emissions Directive, Omnibus VIII proposes targeted tweaks to the environmental management systems required of operators. Crucially, it allows for the use of a single, company-wide environmental management system rather than forcing groups to maintain separate systems for every single installation. It also strips out or lightens certain elements of the system, such as the chemical inventory of hazardous substances, specific risk assessments, and the need for independent audits.
Furthermore, the proposal suggests scrapping the "indicative transformation plans" envisioned under the revised IED, to save operators from yet another layer of planning bureaucracy. For livestock farming, it proposes excluding organic poultry farms from the IED's scope and simplifying how pig farm capacity is calculated by excluding unweaned piglets, ensuring certain farms aren't dragged into obligations entirely disproportionate to their actual environmental footprint.
Finally, it introduces targeted changes to the medium combustion plants directive to ensure that limits designed for traditional plants do not accidentally block industrial investments in decarbonisation technologies, such as hydrogen or oxy-fuel combustion.
For more information: here
9. Omnibus IX - Automotive
The Automotive Omnibus was brought forward by the European Commission on 16 December 2025 as part of the broader Automotive Package, a raft of measures designed to shore up the competitiveness of the European car industry as it transitions to clean mobility. The intervention comes at a time of intense technological, regulatory, and competitive pressure for the sector, marked by electrification, international competition, soaring compliance costs, and the need to fast-track the uptake of low- and zero-emission vehicles. The Omnibus package includes two main legislative proposals: COM(2025) 993, which simplifies technical requirements and testing procedures for motor vehicles; and COM(2025) 999, which exempts certain N2 electric vehicles from having to install and use speed limiters.
According to the European Commission, the Automotive Omnibus should generate around €50.8 million in administrative savings each year. These savings will predominantly come from streamlining testing and type-approval procedures, axing redundant requirements, granting more leeway for electric light commercial vehicles, and better aligning the various technical regulations governing vehicles. The goal is to slash compliance costs for manufacturers, component suppliers, vehicle bodybuilders, and fleet operators without compromising road safety, environmental standards, or consumer protection.
The Automotive Omnibus tweaks the technical rulebook for vehicles to make the regulatory landscape simpler and more coherent for the European motor industry.
Proposal COM(2025) 993 forms the backbone of the package. It amends four legislative acts: Regulation (EC) No 561/2006 on driving times and rest periods, Regulation (EU) 2018/858 on the type-approval and market surveillance of motor vehicles, Regulation (EU) 2019/2144 on general vehicle safety, and Regulation (EU) 2024/1257 (Euro 7). It also repeals Directive 70/157/EEC and Regulation (EU) No 540/2014 concerning vehicle noise levels.
For the uninitiated, type-approval is the process through which a vehicle, system, or component is certified to be placed on the market because it meets European safety, environmental, and performance standards. It is a make-or-break phase for manufacturers, as a vehicle cannot be sold in the EU without it.
A primary focus is electric light commercial vehicles (e-vans). Because batteries are heavy, some electric vans tip over the 3.5-tonne threshold and are legally classed as N2 vehicles (goods vehicles weighing between 3.5 and 12 tonnes). Consequently, an electric van can be shunted into a heavier regulatory class than a diesel van with the exact same load capacity, simply because the battery pushes up the gross weight.
The Commission is therefore proposing to ease certain obligations for e-vans weighing between 3.5 and 4.25 tonnes, particularly regarding tachographs and other rules usually reserved for heavier lorries. The logic is to ensure the shift to electric doesn't accidentally penalise tradespeople, logistics firms, and SMEs who rely on vans for their day-to-day deliveries or technical work.
The proposal also formally introduces the definition of a "small electric car" into European vehicle law. This is key because Europe wants to foster a new generation of smaller, cheaper electric vehicles tailored for urban driving. Defining them legally allows for a bespoke regulatory framework, rather than rigidly applying rules designed for large, complex cars.
Another section deals with testing procedures. For certain checks, especially around noise levels and low-temperature testing, the Commission is proposing to scrap or simplify tests that are now deemed redundant or disproportionate. For instance, under Euro 7, the Type 6 low-temperature laboratory test will be dropped.
The second proposal, COM(2025) 999, amends Directive 92/6/EEC on speed limitation devices. Currently, N2 and N3 vehicles can only be driven if fitted with a speed limiter capping them at 90 km/h.
Again, the issue boils down to battery weight. Some electric vans, despite doing the exact same job as a standard transit van, weigh in over 3.5 tonnes and are classed as N2. They are suddenly hit with extra red tape, including the mandatory speed limiter. This makes them less appealing to businesses, especially micro-enterprises, by ramping up costs and operational constraints.
The proposal would allow electrically propelled N2 vehicles weighing between 3.5 and 4.25 tonnes to be driven without a speed limiter. The aim is to put these vehicles on a level playing field with traditional vans offering the same payload, ensuring electrification doesn't come with regulatory baggage.
This measure is highly relevant for urban transport, last-mile logistics, tradespeople, and delivery services. However, it remains sensitive regarding road safety. Some argue that the exemption creates an unjustified loophole. The Commission counters that any risk is offset by the fact that these new vehicles are still subject to stringent general safety rules, including advanced driver assistance systems and Intelligent Speed Assistance. Both proposals are still winding their way through the legislative process and await the formal positions of the European Parliament and the Council.
For more information: here
10. Omnibus X - Food and Feed Safety
The tenth Omnibus package, presented by the European Commission on 16 December 2025, sets out to simplify European rules on food and feed safety. This is a cross-cutting package dealing with plant protection products, biocides, animal feed, official controls, animal health, and animal welfare. The aim is to strip away procedural complexity and administrative burdens for businesses and authorities, whilst rigorously upholding European standards for safety, consumer protection, animal health, and the environment. The package is comprised of three legislative proposals: proposed regulation COM(2025) 1030, proposed directive COM(2025) 1021, and proposed regulation COM(2025) 1020.
According to Commission estimates, the package should yield administrative savings in the region of €939 million a year. The expected benefits will be felt by both economic operators and public bodies, driven by the streamlining of authorisation and renewal procedures, the axing of repetitive duties, a stronger shift towards risk-based approaches, and the rationalisation of controls and compliance tasks. For agri-food, farming, and livestock businesses, as well as manufacturers of plant protection products, biocides, and feed additives, Omnibus X is highly relevant, as it intervenes in a heavily regulated sector to cut compliance costs without compromising the safety of the EU system.
Omnibus X touches upon multiple segments of food and feed legislation to make procedures, renewals, authorisations, and controls simpler and more proportionate.
The first proposal in the package is COM(2025) 1030, a proposed regulation that modifies a raft of legislative acts directly applicable across Member States. Crucially, it targets plant protection products, maximum residue levels of pesticides, biocides, genetically modified food and feed, feed additives, food hygiene, official controls, animal health, and animal welfare. The dossier follows the ordinary legislative procedure 2025/0410(COD) and is still under review by the European Parliament and the Council.
A primary area of focus involves plant protection products, substances and products used to protect crops from pests, diseases, or weeds. This category encompasses pesticides, herbicides, and fungicides, but also lower-impact products like certain biocontrol substances. The main regulatory framework is Regulation (EC) No 1107/2009 on the placing of plant protection products on the market.
The proposal aims to fast-track market access for biocontrol products and low-risk substances. In practice, the Commission wants to make it simpler and quicker to authorise products deemed less problematic from an environmental and health perspective, thereby offering farmers more sustainable alternatives to traditional chemicals. The envisioned measures include strengthening mutual recognition between Member States and, for some procedures, the possibility of treating the European Union as a single authorisation zone.
Another major point concerns the renewal of active substance approvals. Currently, many approvals are time-limited and require periodic renewal. The Commission wants to shift to a more targeted system for most substances, where full reviews do not happen automatically on a fixed date, but only when scientific evidence or risk profiles actually warrant them. Ad hoc reviews, targeted re-evaluations, and stricter procedures would still remain possible for substances deemed more problematic. For businesses, this could translate into a reduction in the red tape tied to renewal procedures, benefiting both the manufacturers of plant protection products and the national authorities tasked with assessing the dossiers.
The proposal also irons out rules regarding Maximum Residue Levels (MRLs) for pesticides in food and feed. These are the maximum thresholds of plant protection substance residues allowed in a food or feed product. The proposal clarifies certain transitional rules: products that were compliant when they hit the market could remain marketable until the end of their shelf life, avoiding unnecessary waste or uncertainty for operators and distributors. At the same time, the Commission proposes stronger alignment of import rules, ensuring imported products do not benefit from less rigorous conditions than those applied to European producers.
A second block covers biocides, products intended to destroy, neutralise, or control harmful organisms, such as disinfectants, pest control products, preservatives, or other substances used in health, industrial, food, or domestic settings. The proposal introduces a more targeted approach for renewing the approval of biocidal active substances as well, potentially allowing for unlimited approval durations unless safety concerns flag the need for a review or specific time limits.
A third area looks at feed additives, substances added to feed for nutritional, technological, zootechnical, or sanitary purposes. The proposal aims to make authorisation renewals simpler and less burdensome, stripping out repetitive steps when no new risks have emerged. It also opens the door to greater digital labelling opportunities for feed additives, with the aim of cutting the costs of updating, printing, and managing information.
Furthermore, the proposal clarifies the legal status of certain products obtained through fermentation using genetically modified microorganisms. This pertains to food and feed produced using genetically modified microorganisms as production strains, provided the organisms themselves are absent or non-viable in the final product. This clarification serves to eliminate regulatory uncertainty for products derived from industrial fermentation processes, which is highly relevant for enzymes, ingredients, additives, and novel food or feed products.
The proposal also touches upon official controls and laboratories. The objective is to simplify certain accreditation rules for official laboratories while preserving the authorities' capacity to monitor product safety, compliance, and traceability. In this instance, the simplification primarily benefits the competent authorities, but it can also assist businesses through faster and less fragmented procedures.
Finally, the proposal contains measures regarding animal health, animal welfare, and BSE (Bovine Spongiform Encephalopathy). The Commission proposes adapting some surveillance and risk mitigation requirements to reflect scientific advancements and the current epidemiological landscape. Essentially, where the risk is now considered lower or manageable with more targeted tools, certain procedures can be made less burdensome.
The second proposal of Omnibus X is COM(2025) 1021, a proposed directive amending Directive 2009/128/EC on the sustainable use of pesticides and Directive 98/58/EC on the protection of farmed animals. The proposal also repeals two older directives, Directive 82/711/EEC and Directive 85/572/EEC, which are now considered obsolete due to more comprehensive subsequent legislation. The most significant aspect concerns the sustainable use of pesticides. The proposal updates certain provisions in light of evolving agricultural techniques, clarifying that aerial spraying can now include the use of drones. Member States could authorise these applications based on a risk assessment, provided it demonstrates they pose no greater risk to human health or the environment than existing methods.
For farmers and agricultural operators, this topic is relevant because drones allow for highly targeted spraying, especially in hard-to-reach areas, potentially cutting down on waste, costs, and the volume of chemicals used. At the same time, the measure is politically sensitive as it strikes at the balance between technological innovation, environmental protection, and controlling pesticide use.
The proposal then tackles the protection of farmed animals by axing certain obligations deemed duplicative compared to other instruments in European food law. When specific information or controls are already covered by newer EU rules, the Commission proposes sparing farmers or authorities from having to repeat the same compliance tasks in different formats. For agricultural and livestock businesses, this simplification primarily means a reduction in overlapping records, communications, or formal obligations, whilst preserving essential checks on safety and animal welfare.
The third proposal is COM(2025) 1020, relating to the extension of certain data protection periods under the Biocidal Products Regulation, Regulation (EU) No 528/2012. Unlike the rest of the dossiers in the package, this proposal was fast-tracked and has already been adopted as Regulation (EU) 2026/1165. The regulation dates to 20 May 2026 and was published in the Official Journal on 26 May 2026.
To grasp this measure, it is necessary to clarify the concept of data protection. In the biocides sector, companies seeking approval for a substance or product authorisation must submit scientific studies, trials, and data. Data protection rules stop rivals from piggybacking on these costly studies for free for a set period. It is therefore a tool that safeguards the investment needed to generate technical and scientific dossiers.
The problem stems from accumulated delays in the review programme for existing biocidal active substances. Because the review is not yet complete, some data protection periods were due to expire before the regulatory process even concluded. Regulation (EU) 2026/1165 therefore extends certain protection periods until 31 December 2030, aligning them with the extended review programme. The measure offers vital commercial certainty to operators who footed the bill to produce the data and studies. At the same time, data protection also impacts the ability of other operators to enter the market with competing products. The Commission presents the measure as a technical balancing act, pending the broader evaluation of the biocides regulation scheduled for 2026–2027.
Overall, for farming businesses, the primary benefit could come from quicker access to biocontrol products and low-risk substances, fewer registration requirements for certain products, and more pragmatic procedures for using technologies like drones. For manufacturers of plant protection products, biocides, and feed additives, the package may reduce the frequency and complexity of certain renewal procedures, shifting the system towards more targeted, risk-based controls. For national administrations, the impact mainly involves a reduced investigative workload, the elimination of duplication, the simplification of laboratory procedures, and a more efficient use of available resources. The rationale is to allow authorities to focus on the dossiers that matter most from a risk perspective, rather than getting bogged down in automatic renewals or routine compliance tasks.
For more information: here
11. Taxation Omnibus - Simplification of Direct Taxation
Unlike the other Omnibus packages, which target specific industrial sectors, the Taxation Omnibus deals with the horizontal framework of direct taxation for businesses operating cross-border within the European Union. Presented by the European Commission on 24 June 2026, the package includes two proposed Council directives: proposal COM(2026) 560 final, concerning the simplification of the Union's direct tax framework to support EU growth and competitiveness, and proposal COM(2026) 308 final, regarding the recast of administrative cooperation in the field of taxation. Both dossiers follow a special legislative procedure in tax matters, under which the Council acts unanimously after consulting the European Parliament.
According to the European Commission, the package should generate business savings of around €8 billion a year, €3.3 billion of which comes directly from reduced administrative costs. The anticipated benefits are primarily driven by the abolition of certain intra-EU withholding taxes, the simplification of anti-avoidance and interest deductibility rules, stronger tax dispute resolution mechanisms, and the rationalisation of reporting duties under administrative tax cooperation. The ultimate goal is to cut complexity and duplication without weakening the fight against tax fraud, evasion, and avoidance.
The Taxation Omnibus steps into direct taxation and administrative tax cooperation to make operating, investing, and reorganising within the single market simpler.
The first proposal in the package, COM(2026) 560 final, is a Council directive that amends several European acts regarding corporate direct taxation. Specifically, it amends the Parent-Subsidiary Directive 2011/96/EU, the Merger Directive 2009/133/EC, the Anti-Tax Avoidance Directive (EU) 2016/1164, Directive (EU) 2017/1852 on tax dispute resolution mechanisms, and Directive (EU) 2025/50 (known as FASTER), which relates to a faster and safer system for the relief of excess withholding taxes. (eur-lex.europa.eu)
A major element is the elimination of withholding taxes on cross-border payments of dividends, interest, and royalties between companies established within the EU. For the uninitiated, a withholding tax is a deduction applied by the State where the payment originates before the money reaches the beneficiary. Within corporate groups or cross-border business relations, this can create friction, costs, delays, refund requests, and the risk of double taxation. The proposal therefore aims to allow capital, profits, and remuneration to flow much more freely across the single market.
The Commission also proposes expanding the scope of the Parent-Subsidiary Directive to include certain pension institutions. The Parent-Subsidiary Directive prevents profits distributed by a subsidiary to its parent company from being taxed twice in different Member States. Extending this to pension institutions aims to make the tax treatment of certain institutional investors more neutral and to spur long-term cross-border investments.
Another key point concerns investments in tangible assets tied to research and development (R&D). The proposal brings in more favourable tax treatment for specific investments in physical assets used for R&D activities. In practical terms, this could involve machinery, plant, equipment, or production infrastructure dedicated to innovation. The goal is to support the ability of European businesses to invest in applied research, advanced manufacturing, and technological development.
The proposal then tackles the interaction between CFC rules and the global minimum tax. CFC (Controlled Foreign Company) rules serve to counter the artificial shifting of profits to foreign subsidiaries located in low-tax jurisdictions. The global minimum tax, introduced at the European level via the Pillar Two directive, sets an effective minimum tax rate of 15% for large multinational groups. The Commission intends to prevent overlap between these two regimes, easing compliance burdens when the risk of tax avoidance is already caught by the global minimum tax net.
A further block addresses interest limitation rules. These rules restrict the tax deductibility of interest expenses to stop companies from artificially reducing their tax base through excessive debt. The proposal aims to modernise this mechanism, making it more consistent with the current economic context and other anti-avoidance tools already in force.
The Taxation Omnibus also improves tax dispute resolution mechanisms. These are the procedures used when two or more Member States disagree on the allocation of taxing rights, leaving a company at risk of being taxed twice on the same income. The proposal seeks to strengthen these tools to increase legal certainty and cut the time and cost of cross-border disputes.
Finally, the proposal broadens the scope of the Merger Directive, which governs the tax treatment of cross-border operations such as mergers, divisions, transfers of assets, and exchanges of shares. The aim is to simplify corporate reorganisations at the European level, encompassing a wider array of corporate operations and adapting the framework to modern forms of corporate restructuring.
For businesses, the potential impact is substantial. The package can reduce compliance costs, interpretative uncertainties, refund requests, and the risk of double taxation. The benefit will be felt most by corporate groups, companies with subsidiaries in multiple Member States, institutional investors, innovative firms, and operators involved in cross-border restructurings. For SMEs, the direct impact may be more limited, but the simplification of the European tax framework can still encourage investment, scale-up efforts, and cross-border operations.
The second proposal, COM(2026) 308 final, concerns the recast of Directive 2011/16/EU on administrative cooperation in the field of taxation, known as the DAC (Directive on Administrative Cooperation). The DAC governs how Member States' tax authorities exchange information. Over the years, it has been amended multiple times with successive expansions covering, for instance, the automatic exchange of information, tax rulings, country-by-country reporting, potentially aggressive cross-border arrangements, digital platforms, crypto-assets, and the global minimum tax. It is an essential tool for combatting evasion and avoidance, but it can generate complex reporting obligations for businesses, intermediaries, and platforms.
The Commission is now proposing to consolidate the original directive and its myriad amendments into a single, recast text. Simply put, this isn't just a copy-and-paste job to gather scattered rules; the aim is to make the framework far more readable, coherent, and easier to apply for both tax authorities and taxpayers. The Commission presents the recast as a way to reduce duplication, clarify obligations, and improve the effectiveness of administrative cooperation.
The recast of the DAC aims to streamline this framework. Measures outlined include the rationalisation of certain reporting obligations and the elimination of overlaps between different reporting regimes. The proposal also includes an exemption from certain "DAC6" reporting duties for multinational groups that already fall under the global minimum tax rules, and it strips out reporting elements that are no longer deemed strictly necessary. This is particularly relevant for multinational groups, tax intermediaries, consultants, digital platforms, and companies subject to multiple European tax transparency regimes. The recast therefore seeks to preserve the ability of tax authorities to receive useful information, whilst reducing the administrative burden generated by rules that have piled up over time.
For national administrations, a single and more coherent text can facilitate application, reduce interpretative divergences, and make updating IT systems and internal procedures simpler.
In terms of the legislative process, the tax package is still in an early phase. Dealing with direct taxation, both proposals follow a special legislative procedure: the European Parliament is consulted, but the final decision rests with the Council. Furthermore, in this domain, Member States must decide by unanimity, because direct taxation remains a highly sensitive competence closely tied to national tax sovereignty.
For more information: here
Regulatory simplification is one of the central pillars of the European Commission’s agenda for competitiveness and the single market. It forms part of the Competitiveness Compass and the objective of reducing administrative burdens by at least 25% for all businesses and by at least 35% for SMEs. In this context, the Commission has launched a series of ‘Omnibus’ legislative packages, aimed at amending several existing legislative acts in the same policy area simultaneously.
This agenda is also linked to the ‘One Europe, One Market’ Roadmap, the strategic plan agreed on 24 April 2026 by the European Parliament, the Council and the European Commission to strengthen the single market and European competitiveness by the end of 2027. The Roadmap identifies a series of priority legislative and policy initiatives, with clear timeframes and regular monitoring of progress. The dedicated website for the European strategy allows users to track the progress of the main Omnibus dossiers, providing an overview of the state of implementation of the European simplification agenda.
The European Commission has so far proposed the following Omnibus simplification packages:
1. Omnibus I - Sustainability
The first Omnibus package concerned corporate sustainability and was presented by the European Commission on 26 February 2025. The package comprised: the proposal for a ‘stop-the-clock’ directive COM(2025) 80 final, aimed at postponing certain deadlines under the CSRD and the CSDDD; the proposal for a directive COM(2025) 81 final, concerning a substantial revision of sustainability reporting and due diligence obligations; the proposal for a regulation COM(2025) 87 final, dedicated to simplifying and strengthening the CBAM; and a delegated act on the EU Taxonomy, subsequently adopted by the Commission as a delegated regulation.
The Commission has estimated administrative savings of around €4.5 billion per year for the CSRD/CSDDD/Taxonomy component and around €1.2 billion per year for the CBAM simplification.
Omnibus I is the simplification package through which the European Union has acted on the corporate sustainability framework, with the aim of reducing administrative burdens and providing greater legal certainty for businesses. The package specifically concerns the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), the CBAM and the EU Taxonomy, combining time extensions, substantive amendments and changes to technical reporting standards.
The first component to be approved was the so-called ‘stop-the-clock’ directive, adopted as Directive (EU) 2025/794 of the European Parliament and the Council of 14 April 2025, published in the Official Journal of the European Union on 16 April 2025 and which entered into force on 17 April 2025. The measure postponed the application of CSRD obligations by two years for second- and third-wave companies – that is, large companies not yet subject to reporting requirements and listed SMEs – and by one year for the transposition deadline and the first phase of implementation of the CSDDD. The aim was to prevent companies from incurring compliance costs for obligations that were set to be amended by the substantial revision of the package.
For the CSRD, the effect of the ‘stop-the-clock’ measure varied according to the implementation waves. The first wave, relating to large public-interest entities already subject to the previous NFRD, remained unchanged: these companies continued to report in 2025 on the 2024 financial year. For the second wave, covering other large companies, the first reporting deadline was postponed from 2026 (for the 2025 financial year) to 2028 (for the 2027 financial year). For the third wave, concerning listed SMEs, small non-complex credit institutions and captive insurance companies, reporting has been moved from 2027 (covering the 2026 financial year) to 2029 (covering the 2028 financial year). The fourth wave, concerning non-EU firms with significant operations within the Union, has not, however, been affected by the ‘stop-the-clock’ directive and remains set for 2029 for the 2028 financial year.
As regards the CSDDD, the same directive has postponed the deadline for national transposition by one year, from 26 July 2026 to 26 July 2027, and the first phase of implementation for larger firms, from 26 July 2027 to 26 July 2028. The subsequent phases were not directly postponed by the ‘stop-the-clock’ provision, but were subsequently subject to a substantial revision under Omnibus I.
The second component of the package is the substantial revision of the CSRD and CSDDD, adopted as Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026, published in the Official Journal of the European Union on 26 February 2026 and which entered into force on 18 March 2026. In this case, it is no longer simply a matter of postponing the application of the obligations, but of amending their content and scope.
As regards the CSRD, the revision focuses on the scope of the application and the regime applicable to third-country companies. In the original version of the directive, non-EU companies were subject to sustainability reporting obligations if they generated more than 150 million euros in net revenue within the Union and had a significant European presence, through a branch or subsidiary. Under the revision introduced by Omnibus I, the scope is narrowed: the obligations now focus on non-EU multinationals with net revenue of over €450 million within the EU for two consecutive financial years and with a European subsidiary or branch exceeding the €200 million turnover threshold. This therefore represents a significant reduction in the CSRD’s extraterritorial scope, limiting the obligations primarily to large multinationals with a significant economic presence in the European market.
On a different level lies the revision of the European Sustainability Reporting Standards (ESRS). On 3 July 2026, the European Commission adopted the revised ESRS, alongside a new voluntary reporting standard. In this case, the scope of companies subject to the CSRD remains unchanged, but the information that these companies are required to report has been simplified. Based on EFRAG’s technical work, the new standards significantly reduce disclosure requirements, with a reduction of over 60% in mandatory data points and over 70% in total data points.
At the same time, the voluntary standard introduces a proportionate framework for companies not subject to the CSRD, in particular SMEs. This standard should make it easier to respond to requests for ESG information from large companies, banks or investors, whilst at the same time avoiding an excessive knock-on effect of obligations along the value chain. In this context, the principle that companies subject to the CSRD should not require smaller business partners to provide ESG information going beyond the provisions of the voluntary standard is reinforced. The delegated acts on the ESRS are now subject to the usual two-month scrutiny period by the European Parliament and the Council.
As regards the CSDDD, the substantive revision has raised the size and turnover thresholds, focusing obligations on larger companies. The threshold has been raised to 5,000 employees and €1.5 billion in net turnover. The reform has also simplified the approach to mapping and assessing adverse impacts, allowing for greater prioritisation of risks, reducing disclosure obligations towards smaller business partners, and amending certain provisions relating to climate plans, civil liability and penalties.
The CBAM (Carbon Border Adjustment Mechanism) is the EU’s carbon border adjustment mechanism, which requires importers of certain carbon-intensive products to declare and offset embedded emissions, in order to prevent the relocation of production to countries with less stringent climate standards. With regard to the CBAM, proposal COM(2025) 87 final was adopted as Regulation (EU) 2025/2083 of the European Parliament and of the Council of 8 October 2025, published in the Official Journal of the European Union L, 2025/2083, of 17 October 2025, and entered into force on 20 October 2025. The measure exempted a very large proportion of small importers from the CBAM obligations – estimated by the Commission at around 182,000 operators, accounting for approximately 90% of the importers concerned – whilst still ensuring that the vast majority of emissions embedded in imports subject to the mechanism are covered.
Omnibus I also includes a specific measure concerning the EU Taxonomy. In this case, the instrument is not a directive but a delegated act: Commission Delegated Regulation (EU) 2026/73, adopted on 4 July 2025 and published in the Official Journal on 8 January 2026. The measure simplifies the content and presentation of the information to be disclosed on environmentally sustainable activities, reduces the number of data points and introduces materiality criteria to limit reporting on non-material activities.
For further information: here