ACEA position on Omnibus Package 1

ACEA position on Omnibus Package 1

ACEA — 2025-05-05

News from Brussels

The European Automobile Manufacturers’ Association (ACEA) welcomes the Omnibus Package 1, as it will simplify corporate sustainability reporting and due diligence and the EU Taxonomy, providing much-needed regulatory relief, while still supporting climate neutrality commitments.

Simplification in these areas will significantly benefit manufacturers, who have called on the European Commission to boost the competitive capabilities of European industries through a coherent, realistic and simplified regulatory framework.  

However, to ensure meaningful and actual simplification, while maintaining climate goals in mind, ACEA highlights nine aspects that need to be addressed in the ongoing legislative procedure: 

1. Ensure a level playing field until legal clarity is reached: Postponing CSRD for Waves 2 and 3 is welcome, but reporting should also be voluntary for Wave 1, including a pause on new data and audits, until legal clarity exists across all member states.
2. Harmonise reporting timelines across Member States:
   Align report publication timelines across the EU to ensure consistent data collection and avoid requiring reports within six months of fiscal year-end.
3. Clarify expectations for Climate Transition Plans under CSRD/CS3D
   Define and harmonise expectations for climate plans, allowing companies to align with the Paris Agreement based on reasonable efforts, and refer to CSRD/ESRS E1 for consistency, despite limited sector-specific benchmarks.
4. Prevent over-transposition (“gold plating”) under CS3D
   Discourage member states from adding national rules beyond CS3D to avoid legal fragmentation and extra business costs across the EU.
5. Exempt subsidiaries from separate reporting
   Allow group subsidiaries to skip individual CSRD reports if covered by their parent’s consolidated sustainability report.
6. Clarify auditor role and limit checks to every three years
   Avoid excessive audit requirements resembling financial audits; ESG data is still developing, and frequent reviews raise costs without added value.
7. Simplify stakeholder definitions
   Apply a pragmatic stakeholder definition, excluding unions/employees of business partners, and limit consultation to the risk mapping stage.
8. Exempt critical suppliers from suspension rules
   Allow exceptions from suspending suppliers if they provide essential goods or services with no alternatives, such as rare earth materials.
9. Clarify due diligence thresholds and legal language
   Define vague terms in Article 8—replace “plausible information” with “reliable and relevant information”—to support effective due diligence beyond Tier 1.