Danish Position-paper on the upcoming Omnibus Simplification Package
With climate change happening before our eyes, we must deliver on the green transition of European
businesses. Being green has to be a competitive advantage. Ambitious sustainability reporting can show
investors whether a company is green or not. However, ambitious reporting does not mean creating as
many requirements as possible. It means creating a reporting scheme that is focused and works in practice
so companies can actually and easily deliver the required information, and the market can assess it.
The Danish Government welcomes the announcement of an Omnibus Simplification Package. The
proposal must be both ambitious and effective in creating proper simplification for our businesses.
Simplifying sustainability reporting can enhance transparency and drive real impact. By reducing complex
regulation and reporting, we promote alignment around the most important, standardized sustainability
metrics, making it easier to compare progress across companies. This levels the playing field, allowing
businesses genuinely committed to sustainability to distinguish themselves through credible and
consistent data. Cutting administrative burdens and over-reporting not only incentivizes accountability but
also rewards authentic efforts.
To achieve this, we propose three separate, yet interlinked, steps for the Omnibus Simplification Package.
The three steps are designed to deliver immediate relief while allowing enough time for a thorough
simplification exercise across CSRD, CSDDD and the Taxonomy Regulation:
Step one: Postponement and targeted amendments to the CSRD and the Taxonomy Regulation:
➢
Postpone reporting obligations for large companies under the CSRD from 2025 to 2027.
A two-year postponement will provide large companies more time to prepare, ensure a level playing
field across Europe and allow for step 2 (below) to take place. For credit institutions, the reporting
requirements coming into effect from 2025 under the EU taxonomy should similarly be postponed.
➢
Delegate a sufficient mandate to reduce and simplify the number of reporting requirements.
Through a delegated act, the proposal should provide a mandate to cut and simplify the reporting
requirements by 50-75 %. Creating focused, quantifiable, comparable and digital-friendly reporting
should be the main principles.
➢
Review the scope of the CSRD so that fewer companies are covered.
Adjusting the scope of the CSRD in line with the threshold of the CSDDD would create more
proportional requirements while still supporting the overall goals of the regulation.
➢
Delete the sector-specific standards in the CSRD.
The need for obligatory sector-specific standards should be reconsidered. If sector-specific
standards are to be introduced, they must be voluntary.
➢
Postpone the audit requirement in the CSRD by one year.
This would give relevant companies the time to prepare.
➢
Review the scope of the Taxonomy Regulation.
The necessity of mandatory reporting under article 8 should be reconsidered. The burdens
associated with the mandatory reporting does not seem balanced with the usability of the metrics.
The reporting can be difficult to compare across companies as it is subject to the business model
and interpretation by the reporting entity.
➢
Streamline reporting obligations between the CSRD, the Taxonomy Regulation and other financial
regulations (including SFDR, MiFID and CRR 3) to eliminate duplication and overlaps.
Alignment across regulations reduces the need for financial companies to collect information from
non-financial companies outside the scope of the CSRD. Regulations that are not directly within the
scope of the Omnibus Simplification Package should be revisited afterwards to ensure full alignment.
➢
Open to discuss simplifications of the CSDDD.
We are open to discuss ways to simplify the CSDDD while staying true to the original objectives of
the Directive. For instance, making the exemption for financial institutions permanent, so they are
not required to conduct due diligence on their clients and investments.
Step two: Simplify the reporting requirements in the delegated act
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