Date of publication: 16/01/2026
Category: International Policy & Legal Affairs
Prepared by: ESG Expert Team – Carbon Credit Viet Nam Joint Stock Company
In a move aimed at easing the administrative burden on businesses amid economic volatility, on 16/12/2025 the European Parliament officially adopted the Omnibus I package. This decision significantly narrows the scope of the Corporate Sustainability Reporting Directive (CSRD), postpones the reporting timeline for certain groups and simplifies the standards.
For Vietnamese suppliers in global supply chains, this development offers a valuable “breathing space”, but it also carries risks if businesses complacently halt their green transition efforts.
1. CONTEXT: WHEN REALITY COLLIDES WITH AMBITION
The CSRD, regarded as the gold standard for ESG reporting, was initially expected to cover around 50,000 companies in the EU. However, under pressure from compliance costs and the complexity of the ESRS (European Sustainability Reporting Standards), the EU was forced to make adjustments to ensure feasibility and the bloc’s competitiveness.
The adoption of the Omnibus I package is not a retreat from climate commitments, but a strategic recalibration: “Go slower to go more steadily”.
2. THE THREE CORE CHANGES OF OMNIBUS I
2.1. Raising the size thresholds – Narrowing the mandatory scope by 80%
The biggest change lies in the definition of a “large undertaking” subject to reporting. The new thresholds are as follows:
- Headcount: Raised from 250 to ≥ 1,000 employees.
- Net turnover: Raised from €40 million to ≥ €450 million.
According to estimates by KPMG and Deloitte, this adjustment will reduce the number of directly affected businesses in the initial phase by approximately 80%, concentrating supervisory resources on genuinely large multinational corporations (MNCs).
2.2. Streamlining the ESRS Standards
In response to this requirement, EFRAG (the EU’s standard-setting body) submitted a revised draft ESRS on 30/11/2025 with a substantial degree of simplification:
- A 61% cut in data points: From around 1,100 data points down to around 430.
- A focus on core Key Performance Indicators (KPIs) on climate and human rights, eliminating cumbersome descriptive indicators.
2.3. Postponing the reporting deadlines (Delay Timeline)
The implementation timeline has been relaxed to give businesses more time to prepare their data:
- Wave 2 group (large undertakings that have never reported under the NFRD): Postponed to financial year 2027 (reporting in 2028).
- Wave 3 group (listed SMEs): Postponed to financial year 2028 (reporting in 2029).
3. IMPACT ON VIETNAMESE BUSINESSES: OPPORTUNITY OR RISK?
Many Vietnamese exporters may breathe a sigh of relief at this news. However, the expert team at Carbon Credit Viet Nam views it as a “double-edged sword”.
Why Vietnamese businesses should NOT stop?
- The Trickle-down Effect: Although the number of EU companies required to report has fallen, those that remain are all giant multinational corporations (Mega-Corporations) – the largest customers of Vietnamese businesses (such as Adidas, H&M, IKEA, Unilever…). These corporations remain under pressure to report Scope 3 (supply chain emissions). They will therefore not lower their standards for suppliers.
- The rise of the ISSB: While the EU is loosening the CSRD, the global IFRS S1 & S2 standards (issued by the ISSB) are being adopted by 36 countries (including key Asian markets such as Japan and Singapore). If Vietnamese businesses fixate solely on the EU and ignore the globalization of the ISSB, they will lose ground in other markets.
- First-mover Advantage: Competitors’ complacency and “taking a breather” during this period is precisely the opportunity for pioneering businesses to break away. When regulations tighten again in 2027-2028, businesses that already have 2-3 years of data systems in place will be rated far more credible than those just getting started.
4. STRATEGIC RECOMMENDATIONS
Rather than treating this as a reason to delay, Vietnamese businesses should leverage the 2026-2027 period as a “golden window” to strengthen their systems without facing immediate punitive pressure.
Concrete actions:
- Review your data: Use the streamlined ESRS indicator set (430 data points) as a framework for building ESG reports. This is a far more manageable workload than the previous full standard.
- Digitize data collection processes: Move from scattered Excel files to centralized data management platforms.
- Train personnel: Build an internal team well-versed in GRI and the ISSB, ready for future independent audit requirements.
5. CLOSING REMARKS
The EU’s decision is a tactical step back to ensure sustainable strategic progress. For Vietnamese businesses, the message is very clear: Regulatory pressure may have temporarily cooled, but market pressure has not.
International customers will still choose suppliers that are “green”, transparent and equipped with reliable data. Today’s preparation is the insurance policy for tomorrow’s contracts.
About us: This report was prepared by the ESG Strategy & Policy Team of Carbon Credit Viet Nam Joint Stock Company. We help businesses build optimal ESG data strategies that meet international standards (GRI, IFRS S2, ESRS) at the most reasonable cost.
