21.10.2025

Joint industry letter ahead of the plenary vote on the First Omnibus Simplification Package

Dear Member of the European Parliament,

In light of the upcoming plenary vote on the First Omnibus Simplification Package, we write to urge you to reconsider the JURI Committee report in line with Rule of Procedure 72. The concerns we raise are shared by a wide range of European industry stakeholders and reflect calls1 for a clear and proportionate regulation that preserves competitiveness, safeguards legal certainty and reduces unnecessary administrative burdens.

We respectfully ask that you address the following critical issues before the final adoption of the European Parliament’s report:

1. Remove Article 22 in the CSDDD

We urge the removal of Article 22 from the CSDDD to maintain coherence and allow companies to concentrate on a single robust transition plan.
Delete the climate transition plan provisions from the CSDDD. Climate transition plans are already comprehensively addressed under the CSRD and its Climate standard (ESRS E1). Requiring them again in the due diligence directive would create duplication, legal uncertainty, and unnecessary administrative burden, undermining both directives’ purpose and effective implementation. All information on transition planning should therefore remain under the CSRD, the appropriate framework for climate disclosures.

2. No Sector-Specific ESRS Standards

We urge Members of the European Parliament to oppose any reintroduction of such provisions and to keep sustainability standards sector-agnostic, ensuring a single, coherent framework for all undertakings.
Reject any re-introduction of sector-specific sustainability reporting standards, whether mandatory or “voluntary”. We support the Commission’s proposal to remove mandatory sector-specific ESRS under the CSRD, a sensible simplification given that the Sector-Agnostic ESRS already require disclosure against 1,100 and up to 1,800 data points. Introducing sector-specific requirements, even as “voluntary guidelines” under Article 29b(1)(aa), would create excessive and disproportionate reporting burden obligations. In practice, non-binding guidance often becomes a de facto standard, leading to “compliance creep” and inconsistency across sectors. With companies already navigating the first wave of CSRD reporting, further sector-specific layers would only add confusion and complexity.

3. Limit Extra-Territorial reach

We urge co-legislators to find solutions to limit the extra-territorial reach of the CSDDD. This is a concern for both non-EU companies and EU companies with operations outside of the EU, and remains also a concern in the transatlantic relationship, as mentioned in the EU-US Joint Statement on transatlantic trade and investments.

As in our joint letter of June 2025, we reiterate our firm request for a framework that supports ambition through clarity and coherence, allowing businesses to deliver measurable results for the climate and for Europe’s competitiveness.
We respectfully ask you to amend the JURI report accordingly.

François-Régis Mouton
Managing Director – IOGP Europe

Andreas Guth
Secretary General - Eurogas

Liana Gouta
Director General – FuelsEurope

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