COMPLIANCE · EUROPEAN UNION
Narrower scope ≠
lighter proof
The Omnibus package cut the reporting net sharply — but the carbon-border
charge is live, double materiality survived, and the measurement bar didn’t drop for anyone
still in scope, or in a value chain.
OVERVIEW
Fewer firms file. The same carbon has to be proved.
The Omnibus package took the large majority of previously in-scope companies out of CSRD’s direct reach. It is easy to read that as relief. But it did not relax the standard for the companies that remain — and it did not touch the value-chain data requests that reach suppliers far below any threshold.
Meanwhile the carbon-border charge is already pricing the emissions embedded in imports, and it was never part of the Omnibus at all. Fewer firms file — but the ones that do, and the ones feeding them data, still have to measure carbon to a standard that holds
3 REGIMES
In force now
Carrying legal weight today for covered plants.
EU CBAM
Carbon Border Adjustment Mechanism · definitive · importer level
A carbon price on the embedded emissions of imported goods — steel, aluminium, cement, fertiliser, hydrogen, electricity — run as a certificate market.
A carbon price on the embedded emissions of imported goods — steel, aluminium, cement, fertiliser, hydrogen, electricity — run as a certificate market.
WHO
EU importers of covered goods — and, in practice, their non-EU suppliers, whose plant-level emissions set the cost. Small importers sit under a mass-based exemption.
WHEN
Transitional reporting since October 2023; the definitive regime, with financial obligations, began 1 January 2026. Importers authorise, buy and surrender certificates priced off the EU ETS.
REACH
Broader than the UK’s — it includes electricity and uses origin-specific default values.
Where it goes wrong. The importer is liable but the data sits in someone else’s plant, in another country, often with no obligation to hand it over. When actual figures can’t be evidenced the default applies, and defaults are set to be unattractive. The cost of a supplier who cannot prove their number is charged to the importer, and then charged back to the supplier in the next price negotiation.
EU ETS
Emissions trading · installation level
The EU's cap-and-trade market — and the reference price the whole CBAM mechanism is built on.
The EU's cap-and-trade market — and the reference price the whole CBAM mechanism is built on.
WHO
Power, energy-intensive industry, aviation and maritime within the EU, at permitted installation level.
WHY IT MATTERS ELSEWHERE
It sets the CBAM certificate price directly — so any gap between the EU price and another market’s carbon price becomes a cost difference at the border.
Where it goes wrong. Free allocation is phasing down as CBAM phases in, and the two are designed to move together. Installations that budgeted against today’s free allocation are budgeting against a number that is scheduled to shrink — and the exposure lands on the same product lines that CBAM already touches.
CSRD & ESRS
Corporate Sustainability Reporting · post-Omnibus · group level
The EU's sustainability reporting regime — sharply narrowed by the Omnibus package, but retaining double materiality.
The EU's sustainability reporting regime — sharply narrowed by the Omnibus package, but retaining double materiality.
WHO NOW
The Omnibus raised the entry thresholds substantially, removing the large majority of companies from direct scope. Confirm the current thresholds before assuming either way — this is the fastest-moving number on the page.
WHAT HELD
Double materiality survived. The ESRS datapoint set was cut substantially, and revised standards apply from a later reporting year.
Where it goes wrong. “Out of scope” gets read as “off the hook.” It isn’t. In-scope customers still push data requests down the value chain, and a supplier that dropped out of direct scope now has the same questions arriving as a commercial demand instead of a legal one — with no filing deadline to plan against and no template to answer from. The supplier-facing burden arguably grew.
EU Taxonomy
Classification of sustainable activities · group level
The EU's classification system for environmentally sustainable economic activities — the reference that other rules and lenders point to.
The EU's classification system for environmentally sustainable economic activities — the reference that other rules and lenders point to.
WHAT
Defines whether an activity counts as sustainable against technical screening criteria — used in reporting, and increasingly in finance decisions.
CHANGE
The Omnibus added a materiality threshold to ease the reporting burden for smaller in-scope activity.
Where it goes wrong. Alignment percentages get produced at group level and cannot be traced back to the activity data underneath them. The number is fine until a lender asks which turnover, from which site, met which screening criterion — and nobody can rebuild the calculation.
1 REGIMES
In the window
Where the decisions being made now determine tomorrow’s liability.
ETS2 — buildings and road transport
Second emissions-trading system · from 2027
Carbon pricing extended to the fuels used to heat buildings and run road transport — widening carbon cost well beyond heavy industry.
Carbon pricing extended to the fuels used to heat buildings and run road transport — widening carbon cost well beyond heavy industry.
WHEN
Begins 2027, pricing emissions from heating fuel and road transport fuel, charged upstream and passed through.
EFFECT
Energy cost and carbon cost converge for a far broader set of operators — offices, warehouses, cold stores, vehicle fleets — making energy and emissions data a commercial input, not just a compliance one.
Why act before it starts. You will be exposed without being a regulated party — the charge arrives inside your fuel and heat invoices. The businesses that handle it well are the ones that already know their consumption by site and by carrier before the price lands, because that is the only baseline against which any abatement case can be made. Building that baseline takes months. The price does not wait for it.
2 REGIMES
Upcoming
Direction is set. The lead time is the preparation window.
CSDDD
Corporate Sustainability Due Diligence · largest groups only
Mandatory human-rights and environmental due diligence across the value chain — for the EU's largest companies.
Mandatory human-rights and environmental due diligence across the value chain — for the EU's largest companies.
WHO
Post-Omnibus, only the very largest groups by headcount and turnover.
WHEN
Compliance from 2029, with first statements the following reporting year — but value-chain expectations arrive earlier, through in-scope customers.
REACHES FURTHER THAN ITS SCOPE
Even outside the threshold, a supplier to an in-scope company will be asked to evidence its own footprint. The data you build now is what answers that request.
Also on our radar
The Omnibus simplification agenda is not finished — further adjustments to thresholds, datapoints and timing remain live in the legislative process. Separately, CBAM scope extension to additional goods and to downstream products has been raised repeatedly. Neither is settled. Both would change who is caught, and by how much.
Fewer filings, one measurement
CBAM, the ETS, CSRD and the Taxonomy are distinct instruments — but each turns on the same question: how precisely can you measure the carbon in your activity?
The Omnibus changed who has to file. It did not change what a credible number looks like. Build a verification-grade emissions record once and it serves every EU obligation you carry — and answers the value-chain requests that reach you even when the law doesn’t. The paperwork narrowed; the proof didn’t.
HOW WE WORK ON THIS
We build the record,
then file from it
Ventrovia works the measurement layer first, because everything above it —
the filing, the verification, the trade — is only as good as the number underneath.
Measure it properly
Installation-level energy and emissions reconciled to a baseline that a verifier will accept — including the product-level figures a CBAM buyer will ask you for.
File from one source
ESRS datapoints, CBAM declarations, ETS reports and customer data requests drawn from the same record — so the numbers you publish agree with the numbers you send.
Move the number
What the certificate exposure actually costs you, where abatement beats buying, and how ETS2 will land on the parts of the business nobody has modelled yet.
CHECK YOUR STATUS
Which EU regimes apply to you?
Answer a few questions on size, where you make things, what you import and who your customers are — and see what you carry, directly and through the value chain.
THE OTHER SIDE
United Kingdom
Britain runs a separate regime — a CBAM that is a tax, its own ETS, its own reporting standards. See what differs.
