Omnibus & CSRD: Why Carbon Measurement Remains a Competitive Advantage
The Omnibus Eased the CSRD. So What?
Introduction
On 16 December 2025, the European Parliament adopted the Omnibus package. In a matter of votes, the EU dramatically reduced the scope of its two sustainability reporting pillars: the CSRD and the CSDDD. It was a massive rollback. And for many companies, it’s an equally massive temptation to ease off.
That would be a mistake.
Not because regulation will tighten again tomorrow — it might well loosen further. But because the market isn’t pulling back. Agencies, advertisers, procurement teams: the pressure to measure and reduce the carbon footprint of ad campaigns has never been stronger. And it’s no longer coming from Brussels.
What the Omnibus Actually Changes
The Omnibus I package, proposed by the European Commission in February 2025, was the product of mounting political pressure: simplify, lighten the load, restore competitiveness for European businesses. After months of accelerated negotiations — the European Council had pushed for a deal before the end of 2025 — co-legislators reached a compromise on 9 December 2025. Parliament voted a week later.
The changes are significant.
Key Changes in Omnibus I:
- CSRD scope drastically reduced — Threshold raised to 1,000+ employees AND €450M net revenue (cumulative dual threshold). Tens of thousands of European companies fall out of scope.
- ESRS simplified by 70% — From 1,073 to ~320 datapoints. Sector-specific standards scrapped.
- Stop-the-Clock — Two-year postponement for wave 2 companies and listed SMEs.
- CSDDD tightened — Threshold at 5,000 employees / €1.5B net revenue. Climate transition plan obligation removed.
- SME protections — Statutory right to refuse information requests beyond the voluntary SME standard.
Publication in the Official Journal is expected around March 2026, with entry into force 20 days later. Member states will then have 12 months to transpose.
The Political Signal Is Clear. The Commercial Signal Is the Opposite.
At first glance, the Omnibus looks like a retreat. And from a purely regulatory standpoint, it is. Fewer companies in scope, fewer data points to report, extended timelines. The European Commission touts €4.5 billion in administrative savings. The watchword is “competitiveness.”
But here’s what that political framing misses: companies that measure their emissions aren’t doing it to please Brussels. They’re doing it because their clients demand it.
The market is accelerating despite the easing:
Major advertisers are now systematically embedding carbon criteria in their RFPs. Media agencies — Publicis, Dentsu, Havas, GroupM — have made public commitments to reduce plan emissions. GMSF is preparing v1.3 for Cannes Lions 2026. Google opened Carbon Footprint for Google Ads to all advertisers in October 2025.
The market doesn’t retreat because a directive loosens. It accelerates.
Why Advertisers Who Stop Measuring Are Taking a Real Risk
Three concrete reasons.
| Risk | What's Happening | Consequence |
|---|---|---|
| Reputational risk | 62% of Ad Net Zero supporters say sustainability strengthens client relationships (5-year report, Dec. 2025) | No carbon data = measurable commercial disadvantage in RFPs |
| Anti-greenwashing (ECGT) | Directive effective September 2026: bans "carbon neutral" claims without proof, generic environmental claims without data | Real reduction data required. Offsets will no longer suffice. |
| Extraterritoriality | Multinational clients still in CSRD scope + ISSB standards (IFRS S2) in Australia, Brazil, California | Scope 3 data requests persist regardless of European policy |
For a detailed look at advertising implications, see our comprehensive CSRD compliance guide.
What This Means for Digital Advertising
The Omnibus doesn’t change the physics of the problem. Programmatic campaigns continue to generate measurable emissions with every impression, every bid request, every data centre hit. What changes is the motivation.
Before the Omnibus, some companies measured because they had to. After the Omnibus, those who continue measuring do so because it gives them an edge. They optimise supply paths, cut waste on MFA (Made-for-Advertising) sites, choose lower carbon-intensity inventory — and frequently see simultaneous improvements in both ad performance and environmental footprint.
The Carbon Intelligence Thesis:
Carbon measurement is not a compliance burden. It’s a performance lever. Emission reduction and ROAS optimisation are not conflicting goals — they’re two sides of the same coin. Less programmatic waste means fewer emissions and more budget invested in inventory that actually delivers results.
See how carbon-aware bidding is transforming programmatic in practice.
What the Market Expects from You in 2026
March 2026 — Omnibus Published in the Official Journal
- Entry into force 20 days after publication
- New CSRD thresholds: 1,000 employees + €450M revenue
- Companies out of scope breathe a sigh of relief — temporarily
September 2026 — Anti-Greenwashing Directive (ECGT)
- End of "carbon neutral" claims based on offsetting
- Environmental claims require solid evidence
- Advertisers must have real reduction data
2026-2027 — Growing Market Pressure
- GMSF v1.3 expected at Cannes Lions 2026
- RFPs with carbon criteria become the norm
- ISSB (IFRS S2) creates global obligations beyond EU scope
2027-2028 — The Competitive Advantage Crystallises
Companies that have been measuring since 2025-2026 will have historical data, documented reduction trajectories, and a competitive edge that's impossible to replicate in a few months.
Key Takeaways
The essentials in 4 points:
- The Omnibus is a political turning point, not a commercial one. Thresholds rise, datapoints shrink — but the market keeps accelerating its carbon demands.
- Advertisers who measure today are widening the gap. Carbon data is becoming a selection criterion in RFPs and a measurable competitive advantage.
- The anti-greenwashing directive is a game changer. From September 2026, unsubstantiated environmental claims will be banned. Only real data counts.
- Extraterritoriality isn’t going away. Even outside CSRD scope, your multinational clients will still need your Scope 3 data.
The question is no longer “am I required to?” The question is: “can I afford not to know?”
Measure Your Advertising Carbon Footprint
At Carbon Intelligence, we help advertisers and agencies measure, understand, and reduce the carbon footprint of their digital ad campaigns with activity-based precision, aligned with GMSF and the GHG Protocol.
Don’t let the Omnibus lull you to sleep — the market never rests.
Sources and references
- EU Council, “Council and Parliament strike a deal to simplify sustainability reporting,” 9 December 2025
- European Parliament, adoption vote of the Detailed Omnibus Directive, 16 December 2025
- European Commission, Simplification — Omnibus I Package page
- Gibson Dunn, “EU Omnibus Simplification Update,” December 2025
- Morrison Foerster, “EU Sustainability Omnibus I – Detailed Omnibus Adopted,” December 2025
- PwC Viewpoint, “EU reaches compromise on Omnibus proposals,” December 2025
- Sedex, “EU Omnibus I Explained,” January 2026 — ESRS reduced from 1,073 to 320 datapoints
- Ad Net Zero, “5-Year Milestone Data,” December 2025
- Google, “Carbon Footprint for Google Ads” — general availability October 2025
- ECGT Directive (Empowering Consumers for the Green Transition), adopted February 2024, effective September 2026
The US picture is equally complex — federal rollback coexists with binding state laws in California and New York. See our full analysis →
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