Will the EU Omnibus I proposal meet its pupose on climate?
In February 2025, the European Commission published its Europe Union (EU) Omnibus I proposal to reduce administrative burden, boost competitiveness, and enhance investment in a context of growing economic, social and geopolitical tensions.
Some key amendments proposed are to remove the obligation for companies to ‘put into effect’ a climate transition plan (CTP) in Article 22 of the Corporate Sustainability Due Diligence Directive (CSDDD) and even suggested deleting any mention of CTPs altogether.
The EU Omnibus I proposal: Competitiveness vs. Climate action
The proposal has sparked debate between proponents of competitiveness and environmental advocates. The first argues for the need to cut red tape, reduce uncertainty and increase flexibility for businesses. The second stresses the shrinking window of action before climate collapse and escalating impacts.
At the end of October 2025, the European Parliament is expected to adopt its position on the Omnibus I package and enter trilogue negotiations. Then, an important question arises: will the CTP amendments serve their own purpose to protect European businesses and boost competitiveness?
Having worked with businesses for the past seven years and understanding the challenging landscape in which they currently operate, I doubt it. In my view, scraping CTP obligations off the CSDDD text risks leaving companies more vulnerable to market shocks and with no clear direction on how to prepare. Instead, it would make more business sense for EU policymakers to align with the industry trend and work towards a clear mandate, harmonised guidance and continuous improvement.
Climate transition plans: A paper tiger?
A key objective of the EU Omnibus I proposal is to make business compliance more efficient by aligning CSDDD and CSRD and avoiding duplication. While CSRD sets an obligation for companies to disclose a CTP, CSDDD requires them to implement it. However, some argue that the obligation to put into effect a CTP could add unnecessary burden and litigation risks. More precisely, they argue that it would affect companies that follow similar compliance processes in multiple countries with various competent authorities.
And yet, despite organisational complexity and growing public scrutiny, climate pledges are multiplying at the same speed as extreme weather events. Recent data released by the Science Based Target Initiative (STBi) shows that the number of companies with validated climate targets and CTPs has doubled since 2023: 4,122 additional enterprises are moving from words to action.
This trend matches my experience in facilitating the amfori Climate Lab and leading amfori’s working group on climate change solutions for the supply chain. Despite remaining challenges, from tracking emissions to engaging with suppliers in the supply chain, many companies see CTPs as a useful tool. One that manages risks, streamlines internal efforts and reduces their vulnerability to market shocks. For instance, CTPs help companies to assign leadership roles, align corporate objectives and resources across departments, guide partner engagement, innovate on existing/new climate solutions, etc.
More importantly, our discussions with the group consistently show that the adoption and follow-through of climate commitments stimulate collaboration between supply chain stakeholders.
Corporate behaviour at a crossroads: litigation or legislation?
For CTPs to effectively operate across the EU, the legislation must ensure a common framework that aligns climate obligations. Companies need to know their climate efforts will be rewarded, offering them a competitive edge; instead of being punished or devalued as the legislation evolves.
Litigation concerns are real. Recently, the world has seen an unprecedented wave of climate cases against companies (Shell, TotalEnergies, ENI, VW, BNP Paribas, and ING) and governments (Switzerland). On 23 July 2025, the International Court of Justice set a binding obligation for States to prevent climate harm under international law, including a duty to regulate private entities.
Because litigation is likely to increase as scientists link climate damage to individual companies. In this context, and in the absence of a harmonised framework with clear obligations, Article 22 of the CSDDD can help reduce uncertainty and legal risks.
Walking the line between uncertainty and ambition
Clarifying and harmonising climate obligations should theoretically result in better implementation. However, reality may not be as simple: climate change is complex. The unpredictability of contextual factors may discourage companies from setting substantial targets to avoid prosecution for not achieving them.
This is where EU policymakers have an important role to play in defining the right balance between ambition and pragmatism. CSDDD does not expect businesses to find perfect solutions from day one. It clarifies that the CTP provision is “an obligation of means and not of results”. Thus, the legislation allows companies to adapt to their context and focus on continuous improvement rather than strict climate targets achievement.
From burden to boost
Regardless of the output of current policy discussions, rising climate risks (physical, legislative, reputational) demand smart regulation rather than deregulation.
Responsible companies see CTPs not as paperwork, but as important tools to build resilience, earn market trust, and unlock new opportunities. Without a clear mandate for implementation with common guidelines, CTPs risk becoming expensive paperwork, precisely what the Omnibus I proposal aims to prevent.
Legislators now face an important task: ensuring CTPs remain an essential tool to strengthen businesses and boost competitiveness in the EU.
