JBCE Position Paper on the Omnibus I Proposal

On 3 June 2025, JBCE published its position paper on the European Commission's Sustainability Omnibus Proposal (Omnibus I).

JBCE supportd the initiative to simplify and enhance coherence in corporate sustainability frameworks, while emphasising the need to secure legal clarity and operational feasibility, particularly for global companies with complex supply chains.

The position paper presents concrete recommendations addressing key issues, including:

• Clarifying extraterritorial application and managing litigation risks under the CSDDD
• Limiting due diligence scope and preventing cascading obligations on downstream business partners
• Aligning the employee threshold for identifying “large undertakings” of third-country companies with that of EU companies under the CSRD
• Ensuring swift transposition of the “Stop the Clock” proposal and sufficient preparation time for CSRD Fourth Wave companies
• Harmonising key definitions and thresholds between the CSRD and CSDDD, and easing practical challenges in supplier data collection
• Early adoption of implementing acts and guidance, and development of harmonised supplier questionnaires
• Strengthening alignment with international frameworks (e.g., ISSB), and providing clear third-country guidance
• Supporting capacity building and technical assistance for SMEs and third-country suppliers across global value chains

For more information, please contact info@jbce.org