Making sense of the Omnibus Proposal: A conversation with Wim Bartels on EFRAG, ESRS, and what’s next

May 8, 2025
7
min read
Making sense of the Omnibus Proposal: A conversation with Wim Bartels on EFRAG, ESRS, and what’s next - Coolset
Table of contents

Disclaimer: New EUDR developments - December 2025

In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.

Key changes proposed:

  • New enforcement timeline: 30 December 2026 for large/medium operators, 30 June 2027 for small/micro operators
  • Simplified DDS: One-time declarations for small and micro primary producers
  • Narrowed scope: Most downstream actors and non‑SME traders would no longer need to submit DDSs
  • New DDS requirement: Estimated annual quantity of regulated products must be included

These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.

We continue to monitor developments and will update all guidance as the final law is adopted.

Wim Bartels is a prominent figure in EU sustainability reporting, having served as Chair of the EFRAG Sustainability Reporting Board and played a central role in developing the European Sustainability Reporting Standards (ESRS). This article summarizes his perspective on the ESRS, the Omnibus proposal, and the future of sustainability reporting in Europe.

On the development of the ESRS

Bartels has been a key architect of the ESRS framework that underpins CSRD reporting. He has consistently advocated for standards that are both ambitious in their sustainability content and practically implementable for the wide range of companies that fall within CSRD scope. His perspective on the ESRS reflects a balance between the need for comprehensive disclosure and the practical realities of data collection in mid-market and SME supply chains.

On the Omnibus proposal

Bartels has publicly commented on the EU Omnibus proposal and its implications for CSRD. His position reflects the tension between regulatory simplification (reducing burden on companies) and the need for investors, lenders, and other stakeholders to have access to comparable, reliable sustainability data.

Key themes in his commentary on the Omnibus:

  • The reduction in mandatory ESRS data points is a pragmatic response to feedback about reporting burden, but must not undermine the information value for capital markets
  • The VSME provides an important bridge for companies leaving mandatory CSRD scope, ensuring the sustainability data ecosystem doesn’t break down at the supply chain level
  • The amended ESRS should be monitored carefully to ensure they maintain alignment with global standards like ISSB

For the latest on what the amended ESRS require, see our guide to the amended ESRS under Omnibus.

On the broader sustainability reporting landscape

Bartels has emphasized the importance of interoperability between ESRS and global standards, particularly ISSB. He has argued that the EU’s double materiality approach is compatible with ISSB’s financial materiality approach — companies reporting under CSRD can largely satisfy ISSB requirements without additional work on the financial materiality dimension.

What companies should take from his perspective

For companies navigating CSRD preparation, Bartels’ perspective reinforces several practical priorities:

  • The double materiality assessment remains the foundation of CSRD compliance even after Omnibus simplification
  • Supply chain sustainability reporting (including VSME) is essential for maintaining data flows across the value chain
  • The Omnibus changes reduce burden but do not change the fundamental expectation that companies disclose material sustainability information

For the full context on how CSRD scope and timelines have changed, see our guide to CSRD under Omnibus.

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