The EU’s Simplification Agenda: What It Means for Sustainability Legislation

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ABOUT THE AUTHOR

Picture of Arthur Faure

Arthur Faure

Arthur Faure is a public affairs intern at Ohana with expertise in the agri-food sector, sustainability reporting, and circular economy. He works across the transparency and agri-food teams, supporting clients on EU legislation like the CSDDD, CSRD, and EUDR.

The European Union’s sustainability framework has grown rapidly over the past decade, with policies designed to steer businesses towards climate neutrality, circularity, and social responsibility. To boost European competitiveness while safeguarding economic, social, and environmental goals, the European Commission has now turned its attention to reducing regulatory burdens and simplifying EU laws – giving rise to the EU Simplification Agenda.

Simplification comes with the promise to reduce complexity, lower administrative burdens, and make compliance more accessible for businesses. However, it also raises important questions. Will streamlining dilute sustainability objectives, or will it make EU policies more effective in practice? In this article, we explore how the Simplification Agenda is shaping key sustainability files, what is likely to come next, and how businesses should get ready for it.

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch!

An Overview of The EU’s Simplification Agenda

The idea of simplifying European rules is not new. It first took shape under the previous Commission through the “one in, one out” approach, which aimed to balance new regulatory requirements by removing equivalent costs elsewhere. However, the current Simplification Agenda goes a step further. It reflects a broader effort by the European Commission to ease administrative and regulatory burdens, ensuring that EU legislation remains both effective and competitive in a fast-changing global landscape.

As illustrated below, the Agenda sets a target of reducing administrative burdens by 25% for companies, but it should also be reduced by 35% in the case of SMEs.

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The most notable outcomes so far have been omnibus legislative packages, which revise multiple laws simultaneously to reduce burdens and overlaps. The Omnibus I Simplification Package is the flagship example, bundling amendments to sustainability reporting, due diligence, the Taxonomy Regulation, CBAM, and more. Other areas, such as energy and digital policy, are also being examined for possible omnibus treatment.

The Impact of Simplification on Key EU Sustainability Policies

As an overarching Agenda, it would be impossible to individually discuss every aspect in which Simplification is impacting EU legislation. However, we have prepared an infographic to offer you a better overview of the Simplification Agenda’s status in relation to various key EU sustainability files.

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Let’s take a closer look at how simplification is already reshaping some of the bloc’s most important sustainability initiatives.

Corporate Sustainability Reporting Directive

The Corporate Sustainability Reporting Directive (CSRD) requires large companies to disclose detailed information on environmental, social, and governance performance. It entered into force in January 2023, with phased reporting obligations starting in 2024. Under the Simplification Agenda, the Commission has introduced a “stop-the-clock” mechanism to delay certain detailed reporting obligations. It also reduced the Directive’s scope, removed the adoption of sector-specific standards, and scaled back disclosure requirements.

Corporate Sustainability Due Diligence Directive

The Corporate Sustainability Due Diligence Directive (CSDDD) requires companies to identify, prevent, and mitigate human rights and environmental risks across their value chains. Adopted in 2024, the directive’s implementation has since been adjusted under the Simplification Agenda. The entry into application has been delayed by one year, and discussions between the European Parliament and the Council are ongoing regarding a reduced company scope. Other proposed measures include limiting due diligence obligations to direct suppliers, narrowing stakeholder engagement requirements, and restricting data requests to information already covered by the voluntary SME reporting standard.

EU Taxonomy

The EU Taxonomy establishes a classification system for environmentally sustainable economic activities. Its framework has been in force since 2020, with delegated acts progressively defining technical criteria. Under the Simplification Agenda, the Taxonomy is being revised in line with the changes made to the CSRD. Companies will be allowed to report partial alignment, and a 10% revenue materiality threshold will apply. The “Do No Significant Harm” criteria are also being simplified to make the framework more practical for reporting and verification purposes.

Green Claims Directive

The EU Green Claims Directive aims to regulate the use of environmental claims made to consumers, requiring independent verification of such claims. However, the proposal faced strong political resistance, with a blocking minority in the Council and lack of support from the center-right European People’s Party in Parliament. In June 2025, the European Commission announced its intention to withdraw the proposal, citing concerns that it might be at odds with its Simplification Agenda. However, the formal withdrawal has not yet taken place, and the file remains on hold until a final decision is confirmed.

EU Deforestation Regulation

The EU Deforestation Regulation (EUDR) seeks to prevent products linked to deforestation from being placed on the EU market. It entered into force in 2023, with application beginning in December 2024. In 2025, the Commission introduced simplification measures to ease implementation, including the reuse of due diligence statements, simplified obligations for downstream operators, and annual rather than per-shipment submissions. The implementation timeline is being extended a second time, with large companies likely required to comply from December 2026 and micro and small enterprises from December 2027. Further simplification by the European Parliament and the Council is still a possibility.

Check back with us next month as we plan to take a closer look at the EU Deforestation Regulation.

EU Carbon Border Adjustment Mechanism

The EU Carbon Border Adjustment Mechanism (CBAM) imposes a carbon price on imports of selected goods to prevent carbon leakage and align costs between EU producers under the Emissions Trading System and non-EU imports. Under the Omnibus I package it has been the target of important simplification measures. These include a new de minimis mass threshold of 50 tonnes per importer per year, under which many small or occasional importers would be exempted from CBAM obligations. For importers above this threshold, simplifications have been proposed for the authorisation process, emission calculation, verification requirements, and financial liability rules.

Common Agricultural Policy

The EU Common Agricultural Policy (CAP) provides financial support to EU farmers and sets rules for payments and environmental conditionality. In May 2025, the Commission presented a simplification package, known as the Agriculture Omnibus (Omnibus III), to reduce administrative burdens. It proposes higher lump-sum payments for small farmers, streamlined environmental requirements, fewer on-site inspections, and greater flexibility for Member States when updating their CAP Strategic Plans.

Other Policies Likely to Be Affected by Simplification

The next stage of the Simplification Agenda is emerging through several cross-cutting omnibus proposals, such as the Environmental Omnibus, the Food and Feed Safety Omnibus, and the Chemicals Simplification Omnibus Package. These initiatives demonstrate that simplification is not limited to one policy area; it cuts across multiple sectors and legislative frameworks. While some omnibuses focus on sustainability, others address different policy fields, reflecting the Commission’s wider goal of reducing regulatory complexity across the board.

Even within sustainability-related legislation, simplification can occur through different channels. For instance, secondary legislation and implementing acts may also be revised to introduce simplification measures, such as streamlining reporting obligations or clarifying technical rules. The upcoming Digital Product Passport is one example where design details within secondary legislation could be adjusted to make compliance more straightforward.

Beyond the measures already amended, many existing policies are strong candidates for simplification, and several upcoming initiatives will include simplification elements. These include:

Turning Simplification into Strategy: Our Analysis and Recommendations

Simplification is a necessary step to make EU law more practical and accessible. However, the way in which it is designed and applied matters.

The EU’s current approach to simplification has raised concerns about process and transparency. Several omnibus initiatives have advanced quickly, with limited consultation and impact assessments. This pattern has even prompted an inquiry by the European Ombudsman to look into the Commission’s failure to comply with its Better Regulation guidelines in preparing a legislative proposal on corporate sustainability reporting and due diligence.

We believe that simplification cannot mean deregulation and should not come at the expense of our sustainability objectives. Simplification that supports pragmatic implementation of EU rules should be supported, but not deregulation that targets the bloc’s sustainability objectives. In fact, the EU’s long-term competitiveness depends on embedding sustainability in its economic model, and lowering ambition would be counterproductive.

Staying Ahead of Simplification

As the Simplification Agenda continues to develop, businesses have an opportunity to shape how it takes form and to use it as a moment to strengthen their positioning within the EU’s evolving sustainability framework. Here are some recommendations for businesses:

  • Track the process, not just the outcomes: Monitor how the Simplification Agenda develops across sustainability files that affect your operations. Many of the most significant changes happen before final adoption.
  • Engage early and strategically: Participate in consultations and dialogues to ensure your priorities are reflected in future revisions.
  • Define your position clearly: Identify where simplification offers genuine relief and where it could weaken the standards that underpin your competitiveness and reputation.
  • Build alliances: Coordinate with peers, sectoral platforms, and trade associations to strengthen your voice in the policymaking process.
  • Plan ahead: Anticipate regulatory adjustments, assess possible business impacts, and prepare your advocacy and compliance strategies in parallel.

Key Takeaways

The EU’s Simplification Agenda is already reshaping sustainability legislation and will continue to do so throughout this mandate. Timelines, reporting requirements, and compliance obligations are all being revisited, with omnibus initiatives set to accelerate this process. For businesses, this means that monitoring developments is not enough – strategic engagement is essential to stay aligned with evolving rules and ensure priorities are defended.

The pace of change will be fast, but you do not need to navigate it alone. Our experts can help you understand how the Simplification Agenda affects your business and design a strategy that makes sense for your priorities. Get in touch with our team and let’s get started!

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