EU Omnibus Procedure & CBAM – What is now changing for companies
Ursula von der Leyen announced the “omnibus procedure” as early as 2024. It is intended to introduce changes to several existing regulations at the same time in order to reduce the administrative burden for SMEs. This primarily affects sustainability laws such as the EU Supply Chain Directive (CSDDD), the Corporate Sustainability Directive (CSRD) and the Carbon Border Adjustment Mechanism (CBAM).
Recap CBAM - What has happened so far
The Carbon Border Adjustment Mechanism is a key instrument of EU climate policy that aims to reduce CO₂ emissions and create a level playing field between EU companies and foreign producers. The introduction of the CBAM is intended to prevent so-called carbon leakage effects, whereby companies relocate their production to countries with less stringent environmental regulations in order to save costs. At the same time, the equal treatment of imports and domestic production is to be promoted.
CBAM particularly affects importers of emission-intensive products, including.
- Cement
- Electricity
- Fertilizer
- Iron and steel
- Aluminum
- Hydrogen
These product groups were selected because their production is associated with high CO₂ emissions and they therefore pose an increased risk of carbon leakage.
Companies that import these goods into the EU must.
- Submit emissions reports: Provide detailed information on the CO₂ emissions contained in the imported products.
- Purchase CBAM certificates: From 2026, purchase certificates in line with reported emissions to offset CO₂ costs.
- Ensure data quality: Ensure emissions data is accurate and verifiable to ensure compliance and transparency.
In our detailed articles on the CBAM reporting obligation and the CBAM standard values, we explain the details of CBAM in detail.
EU Omnibus procedure summarized
With the omnibus package, the EU Commission is responding to increasing criticism of excessive bureaucracy in sustainability reporting. The aim is to significantly reduce the burden on companies – especially small and medium-sized enterprises – without losing sight of the EU’s ambitious climate targets. In addition to the Corporate Sustainability Reporting Directive (CSRD) and the Supply Chain Directive (CSDDD), the CBAM system was also scrutinized.
The following sections provide a concise overview of the key contents, timetables and effects of the EU omnibus procedure.
Before the omnibus package can enter into force, the European Parliament and the Council must approve the Commission proposal. It should therefore be noted that this is currently only a legislative proposal.
Publication:
- The omnibus package was presented by the European Commission on February 26, 2025.
Temporal focus on CBAM:
- The simplified rules for CBAM are to take effect after the end of the transition phase (October 2023 to the end of 2025).
- A comprehensive review of the CBAM system will take place in the course of 2025.
- A new legislative proposal for the further development of the CBAM is planned for early 2026.
With the new EU omnibus package, the EU Commission wants to significantly reduce the bureaucratic burden associated with the carbon border adjustment mechanism (CBAM).
- Small importers, especially SMEs, are to be exempt from the obligations in future if they import less than 50 tons of CBAM goods per year. This also exempts them from the CO₂ reporting obligation – this affects around 90% of all affected companies without weakening climate targets: 99% of CO₂ emissions will continue to be recorded.
- For companies that are not affected by the above-mentioned exemption, the reports, calculations and financial obligations are to be simplified. At the same time, the EU wants to better prevent abuse – through stricter rules and cooperation with the national authorities.
So far, no changes to fines or sanctions have been listed in the EU Commission’s proposal. However, it is to be expected that the simplifications will also ensure proportionality in enforcement.
One thing is clear: companies that are still subject to CBAM must continue to expect sanctions for breaches of reporting and certification obligations.
Impact of the EU Omnibus on CBAM
With the omnibus package, the EU is making targeted adjustments to the CBAM system in order to reduce bureaucracy and ease the burden on small companies – without losing sight of the goal of effective carbon border adjustment. The changes affect both the scope of application and the practical implementation for affected importers. SMEs in particular will benefit from clear thresholds, reduced obligations and simplified procedures. However, the changes will also make things easier for companies that remain subject to CBAM – from the calculation of emissions to the obligation to register.
The key changes and their specific impact on CBAM applicants, reporting and issuance costs are explained in more detail below.
Within the framework of the CBAM requirements, the focus is on smaller units – in particular on companies that only import CBAM goods occasionally or in very small quantities.
Until now, even smaller companies that imported small quantities of CBAM-relevant products (e.g. steel, aluminum, cement) had to record and report complex emissions data – an enormous burden, especially for companies without large compliance departments.
The omnibus procedure will now provide targeted relief for SMEs:
- 50-tonne threshold per year:
Companies that import less than 50 tons of CBAM goods per year are exempt from all CBAM obligations – including the costly CO₂ reporting. This applies to around 90% of importers in the EU, most of whom are SMEs. - No more indirect compulsion:
SMEs that are part of the supply chains of larger companies will no longer automatically have to provide emissions data in future, unless this is regulated by voluntary standards. This avoids the so-called “domino effect”. - Simplified processes for affected SMEs:
Companies that nevertheless remain subject to CBAM benefit from simplified procedures – for example with regard to the obligation to register, the calculation of emissions or the purchase of certificates.
A central concern of the omnibus package is to further reduce the administrative burden for companies – especially in the case of complex reporting obligations such as those in the CBAM system. To this end, it has been clarified that CBAM notifiers can delegate certain tasks to external service providers or partners.
In concrete terms, this means
Companies that are obliged to submit emissions reports can commission third parties with the technical processing – for example, for the collection, calculation and reporting of emissions data or for the purchase and management of CBAM allowances.
The legal responsibility remains with the notifier itself. They must ensure that the commissioned third parties act correctly, on time and in accordance with EU requirements. Delegation therefore does not release the applicant from the obligation to monitor and ensure quality.
This option is an important lever for small and medium-sized companies in particular that do not have their own resources in the area of CO₂ accounting or customs clearance to meet the requirements professionally and efficiently – without having to build up internal expertise.
A central point of criticism of the CBAM to date has been the time-consuming determination of CO₂ emissions generated during the production of goods – so-called “gray” emissions. Data collection was often complex, especially for small import volumes or supply chains that were difficult to access.
The Omnibus package simplifies things considerably here:
- From 2027, companies will be able to use default values for emissions published by the EU Commission. These so-called default values will be calculated for certain product groups and third countries on the basis of publicly accessible and reliable data. Instead of individual calculations and time-consuming supplier verification, it is then sufficient to use these average values. This not only saves time and money, but also reduces the risk of incorrect information. The EU also reserves the right to update the standard values regularly – for example, in the event of changes in emissions intensity or trading patterns.
The omnibus package provides further relief for companies through the extended crediting of carbon prices already paid abroad. Previously, importers had to go to great lengths to prove that a carbon price had already been paid in the country of origin of their goods – for example through national emissions trading systems or CO₂ taxes.
From 2027, the verification procedure is to be significantly simplified: The EU is to publish average CO₂ prices of selected third countries, which companies will be allowed to take into account directly when calculating their CBAM obligations – without individual verification. If the amount can be calculated accurately and is lower than the standard value, the actual CO₂ price can be used in the calculation.
Advantages for companies:
- Transparency & predictability in cost calculation
- Reduced financial outlay, as duplicate surveys are avoided
- Fewer bureaucratic hurdles when proving third-country costs
This measure ensures greater fairness in global trade and protects European companies from being unnecessarily burdened despite the climate protection efforts of their supplier countries.
A central element of the CBAM is the purchase of CBAM certificates, which importers use to offset the CO₂ emissions of their imported goods. The sale of these certificates was originally scheduled to start in 2026. This date has now been officially postponed as part of the omnibus package:
The sale of CBAM certificates begins in February 2027.
This postponement gives companies more time to prepare themselves organizationally, technically and financially for the mandatory phase of the CBAM. This is because from the time of certificate sales, all importers subject to the CBAM must report annual emission volumes and purchase corresponding certificates.
The transition phase, during which companies “only” have to report but not yet purchase certificates, will remain in place until the end of 2025. The year 2026 serves as an additional preparation period – a relief, especially for smaller companies and those with complex supply chains.
Who benefits from the EU Omnibus procedure?
The omnibus package brings a number of simplifications – but not all companies benefit to the same extent. The main focus of the relief is on:
01
02
03
04
CBAM is coming - how to prepare properly for 2025
The CBAM regulations sound complex, but with the right structure they are easy to manage. In our practical article, we show you how to make your company CBAM-ready in 5 steps – compact, easy to understand and implement.
Conclusion: EU Omnibus Regulation as a relief for all CBAM-affected SMEs
With the EU omnibus package, the Commission is sending a clear signal: climate protection and competitiveness should be more closely aligned in future. The adjustments to the CBAM provide urgently needed relief – especially for small and medium-sized enterprises. Less bureaucracy, clearer thresholds and more practicable calculation methods make the carbon border adjustment system more manageable and transparent.
Despite the simplifications, CBAM remains a challenging instrument. Companies should use the additional leeway now to review their internal processes and prepare for the mandatory phase from 2027 at an early stage. Because one thing remains: Those who are well prepared will not only ensure regulatory compliance – but also long-term competitiveness.
