Omnibus

As part of Sustainable Development Committee of the Polish Association of Listed Companies In December 2024, we developed a position on possible changes to EU regulations on sustainable development. At the beginning of January 2025, it was further refined with the participation of the Association's Management Board and sent to the European Commission on January 10, 2025. It contains four main proposals, ten detailed legislative proposals, and five non-legislative proposals that the Commission could take to facilitate sustainability reporting for companies.

The main demands concerned:

• maintaining and improving the main elements of the sustainable finance system (which consists of CSRD, Taxonomy, SFDR, BMR, and CRR) so that companies' access to sustainable financing is not impeded;
• ensuring the certainty and predictability of legal regulations and making any changes after first assessing the associated costs and benefits;
• ensure that the original promise of the CSRD directive is kept, namely that standardized sustainability reporting will put a stop to companies being inundated with dozens and hundreds of forms and questionnaires on ESG data;
• the fastest possible implementation of ESAP and tagging of reports with XBRL tags, while maintaining appropriate transition periods.

Last week (until January 17, 2025), the Ministry of Development and Technology collected proposals related to the potential scope and content of the Omnibus. I expect that the ideas gathered may be used during the meeting of the Economic and Financial Affairs Council scheduled for January 21, 2025, as part of the deliberations of the Council of the European Union. One of the items on the agenda There is a discussion about improving competitiveness by simplifying, streamlining, and reducing regulatory burdens.

On Monday, January 13, 2025, I had the pleasure of participating in a meeting organized by Frank Bold with representatives of the cabinets of Commissioners Albuquerque and Dombrovskis. During the meeting, we presented conclusions and proposals for solutions that could be included in the Omnibus. The proposals I put forward were based on the position I described above.

Representatives of the European Commission did not, of course, comment explicitly on the proposal, but I got the impression that:

• welcome any proposals to extend existing transitional arrangements or introduce new ones;
• are aware that proposing changes to the rules before the end of the first full reporting cycle is very risky;
• understand the strong market need for the official release of the VSME standard (a voluntary standard that could be used by all micro, small, and medium-sized enterprises) as soon as possible.

The omnibus bill is now here and will be the subject of much speculation and lobbying efforts in the coming weeks. This will be followed by several months of negotiations in Parliament and the Council. That is why I try to write only about facts in this newsletter, or possibly about those aspects of the upcoming regulation that I believe are highly likely.