Redrawing Lines in the Sustainability Debate

Anna Davreux Senior Vice President and Partner, FleishmanHillard EU

Thomas Coutinho Lehnen Senior Account Executive, FleishmanHillard EU

The end of the year is in sight, and the political winds blowing across Brussels are not just shifting – they are reshaping the foundations of majority-building in the European Parliament.

What began in November as a controversial vote on the Omnibus package has now culminated, in early December, in an interinstitutional (trilogue) agreement that both reflects and tests these new political dynamics. When the European Parliament adopted its position on the Omnibus reforms to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), the way the vote was won became the story: for the first time this term, the Parliament’s largest group, the centre-right European People’s Party (EPP), secured a majority not through the centrist coalition that underpins the von der Leyen Commission, but through a partnership with the European Conservatives and Reformists (ECR) and the far-right Patriots for Europe (PfE). That majority delivered a clear outcome in Plenary and signalled that the EPP now has an alternative route to parliamentary victories – one that moves right rather than towards its traditional allies in S&D and the liberal Renew Europe.

This precedent carried directly into the atmosphere surrounding trilogues. Civil society organisations, trade unions, and several MEPs from S&D, Renew, and the Greens warned that the Parliament's right-leaning majority had set the tone for the negotiations, especially on climate transition planning and the extent of due diligence obligations. At the same time, Member States, led by The Danish Council Presidency, entered the process with their own priorities rooted in burden reduction and competitiveness. Although Council and Parliament positions were already relatively aligned on areas such as CSDDD scope thresholds and the removal of harmonised civil liability, the political context made compromise more sensitive, with climate obligations, impact identification, and the scale of reporting requirements emerging as the most contentious issues.

The trilogue outcome now confirms how these dynamics ultimately settled. Politically, the deal broadly mirrors the direction set by the Parliament’s right-leaning majority: reporting requirements are cut back, climate transition planning obligations under CSDDD are removed entirely, and the due diligence regime is reframed around a targeted scoping exercise rather than full value-chain mapping. At the same time, the final agreement does not land fully on Parliament’s terms. The CSRD scope threshold – set at 1,000 employees and €450 million turnover – aligns instead with the Commission and the Council, not with the Parliament’s proposed 1,750 employees. The exemption for financial holding companies and transition relief for “wave one” reporters falling out of scope reflect institutional balancing rather than ideological victory. Similarly, the CSDDD’s final scope of 5,000 employees and €1.5 billion turnover, its penalty cap of 3% of global turnover, and the postponement of application to 2029 all reflect a negotiated centre of gravity shaped jointly by Council caution and Parliament’s simplification ambitions.

The result is a package that carries the imprint of the new majority dynamics. It is a settlement shaped partly by the Parliament’s right flank, partly by the Council’s long-standing focus on burden relief, and partly by Commission insistence on preserving the core structure of both directives. As Omnibus now reaches its conclusion, the political question that lingers is not just how the sustainability framework has changed, but how the EPP’s experiment with alternative majority-building will reverberate across the next wave of files. With negotiations on major reform proposals still ahead – including the SFDR review and further adjustments to the Taxonomy – the centre is no longer the Parliament’s default landing ground. Whether this becomes a one-off deviation or the beginning of a more structural realignment will shape the political dynamics of EU sustainable finance policy throughout 2026.

The SFDR review proposal: resetting the architecture

The European Commission has now released its proposal for the review of the Sustainable Finance Disclosure Regulation (SFDR), marking the beginning of a new negotiation cycle on one of the EU’s most consequential sustainable finance files.

The proposal introduces a fundamental redesign of the framework, replacing the Article 8/9 system with three product categories: Transition, ESG Basics, and Sustainable. These categories encompass any financial product making sustainability-related claims, while products outside the system would be subject to strict naming and marketing prohibitions. This shift reflects the Commission’s ambition to deliver a more intelligible, more enforceable, and more coherent transparency regime – one designed both to curb ESG overstatement and to support comparability for investors across jurisdictions.

This redesigned architecture also aims to connect more logically with the wider EU sustainable finance framework, with new provisions establishing a clearer link with the Taxonomy Regulation, the EU Climate Law, and the existing architecture of the CSRD. They also attempt to respond to years of market feedback on ambiguity, disproportionate disclosure burdens, and conceptual confusion around notions such as “sustainable investments” and the “Do No Significant Harm (DNSH)” criteria. The Commission’s approach is to reduce conceptual noise and ground the system in proportionate, objective criteria tied to category-specific objectives.

What changes — and why they matter

At the heart of the Commission’s proposal is a clearer articulation of what the three categories are intended to achieve. Sustainable products are designed to channel capital into activities that make a measurable contribution to environmental or social objectives. Transition products are aimed at financing the shift of high-emitting or hard-to-abate sectors toward credible decarbonisation pathways. ESG Basics products, meanwhile, are intended to capture strategies with a sustainability component but without the ambition or investment profile required for the other two categories.

Against this backdrop, the proposal introduces several substantive changes that reshape how the categories operate, who qualifies, and what must be disclosed. One of the most important is the narrowing of the new “environmental objective” definition to the six existing Taxonomy environmental objectives. The eligibility criteria for Transition products require alignment with the EU Climate Law objective of climate neutrality by 2050 and excluding companies deriving revenue from coal or engaged in fossil-fuel expansion. These refinements help distinguish Transition products from Sustainable products while setting a clear credibility threshold for both.

The ESG Basics category, although designed to be broad, is subject to its own exclusions, including a limit on coal-related revenues, reflecting the Commission’s intention that even the least stringent category maintain baseline integrity. Despite initial expectations, the proposal keeps the Principal Adverse Impacts (PAI) framework at product level – now with voluntary indicators and without the prescriptive obligations of SFDR I – and retains certain taxonomy-linked disclosures for products pursuing climate mitigation objectives, requiring an explanation of how taxonomy-aligned investments contribute to the 70% portfolio threshold.

Additional adjustments further streamline the regime. The proposal now eliminates several entity-level disclosure requirements and expands grandfathering for closed-ended funds created before the new rules apply. Taken together, these changes point toward a system that is more targeted, more grounded in product-level outcomes, and less dependent on broad conceptual definitions.

How the proposal aligns with the broader simplification agenda

The Commission’s SFDR review is designed not in isolation, but as an integral part of the EU’s wider simplification agenda. The ban on national gold-plating directly supports the Commission’s broader effort to limit fragmentation across Member States, an issue that has been repeatedly raised by industry and regulators alike. The narrowing of scope – in particular, the removal of financial advisers and insurance intermediaries – also mirrors the targeted reduction in complexity observed in other sustainability files.

Equally important is the Commission’s effort to restore trust. SFDR has suffered reputational damage in recent years, with concerns about inconsistent implementation, over-claiming, and a lack of alignment with other EU legislation. By embedding objective criteria, setting portfolio thresholds and tightening exclusions, the proposal seeks to deliver a clearer and more credible system without replicating the compliance burdens of SFDR I.

Where the politics leaves policy next quarter

Heading into Q1 2026, Omnibus is set to be published into law. The SFDR review proposal, meanwhile, enters its early negotiation phase. While more targeted and less ideologically charged than Omnibus I, its trajectory will still be shaped by the Parliament’s new political arithmetic. How the EPP chooses to assemble majorities – and whether the centre-right continues to look rightward or returns to its centrist partners – will influence the pace, ambition, and clarity of the negotiations in the months ahead.

Tracking the reshape: where do we stand?

Policy Intervention
Description
State of Play
RAG (Progress)
Omnibus: Stop-the-Clock Directive (Level 1 legislation)
The directive postpones by two years the CSRD requirements for large companies yet to report and listed SMEs, and by one year the transposition and application of the CSDDD.
Approved by both the European Parliament and the Council, national transposition is required by 31 December 2025.
•
Omnibus: Substantive amendments (Level 1 legislation)
This proposal encompasses changes to the CSRD, CSDDD, and EU Taxonomy in relation to scope, due diligence obligations, and precise reporting requirements.
Trilogue negotiations concluded in December, with the revised texts now set to be published into law.
•
ESRS amendments (Level 2 legislation)
Amendments to the ESRS are linked to reporting requirements under the CSRD. The Commission has tasked EFRAG with streamlining the number of datapoints and aligning the ESRS framework with international standards.
EFRAG recently submitted its revised standards and to the Commission, which will serve as basis for a delegated act to amend the ESRS. This adoption would have to be followed by co-legislator scrutiny.
•
Taxonomy (Level 2 legislation)
This legislative file proposes amendments to the EU Taxonomy delegated act focusing on simplifying reporting templates, DNSH simplification, and a de minimis financial threshold of 10%.
The Commission adopted its revised delegated act in July. Currently in the final stages of co-legislator scrutiny, the new revised rules are expected to soon enter into force, to apply from 1 January 2026.
•
Review of the Sustainable Finance Disclosure Regulation (SFDR)
The review aims to simplify the existing framework, reducing legal ambiguities and compliance costs and improving clarity. This includes the introduction of a new category system, the removal of legacy concepts, and a ban on gold-plating.
The Commission put forward its review proposal on 20 November 2025 and negotiations in Parliament and Council are expected to start relatively soon.
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