2025 is a reset year for sustainability reporting in Europe. The European Commission has proposed an Omnibus package to simplify parts of CSRD and delay it for most organizations, changing who reports when and what many companies need to prioritize right now. Some deadlines stay; others shift. And Scope 3 remains material for most food businesses
Below, we’ll break down what’s changed, what hasn’t, and how food businesses can prepare pragmatically in 2025.
The Corporate Sustainability Reporting Directive (CSRD) establishes a common EU rulebook for sustainability disclosures, utilizing the European Sustainability Reporting Standards (ESRS). In February–April 2025, the Commission proposed a “simplification Omnibus” to reduce near-term scope and postpone later reporting waves to cut red tape and focus on the largest companies first.
• Scope reduction (proposal): In the near term, only companies with >1,000 employees and meeting either €50m+ turnover or €25m+ balance sheet would remain in scope — an ~80% reduction in immediately covered companies. (Subject to adoption.)
• Stop-the-clock / delays (proposal): Later CSRD reporting waves are postponed by ~2 years; Wave 1 stays on the original schedule.
There’s an active debate surrounding these changes, including scrutiny from the media and NGOs. Regardless, large foodservice operators and listed groups remain first in line to report; smaller suppliers may be outside immediate scope but will still be asked for verifiable data by in-scope customers.
• Wave 1 (unchanged): Companies previously under the NFRD report FY2024 in 2025.
• Later waves:
→ Large undertakings (Wave 2): postpone to report FY2027 in 2028 (instead of FY2025 in 2026).
→ Listed SMEs (Wave 3): similarly pushed back by about two years, with publication from 2029.
Use these as planning assumptions and update them when the final legal acts are adopted.
You report using ESRS (e.g., ESRS E1: Climate). Two essentials matter most in 2025:
• Materiality first: CSRD starts with double materiality—what’s material to people/planet (impact) and to your business (financial). Scope 3 is reported when material. F or food businesses, it usually is, because agriculture, ingredients, packaging, transport, and waste dominate value-chain emissions.
• Assurance-ready evidence: Auditors will expect traceable methods, sources, and controls behind the numbers, not just totals. Build the audit trail as you build the data.
1) Confirm applicability and timing
If you are in Wave 2, start getting ready. 2028 seems far away, but it is closer than you think. Setting up the reporting machine can be challenging, and it is better to start now than get left behind.
2) Baseline emissions using recognized methods
Build a Scope 1–3 baseline using GHG Protocol-aligned methods. In food, assume Scope 3 will be material; plan accordingly (ingredients, packaging, logistics, waste).
3) Map disclosures to ESRS
Translate your climate work into ESRS E1 (and evaluate if other topical standards are material to your business). This keeps a straight line from data to disclosure.
4) Strengthen data systems and supplier engagement
Replace spreadsheets with systems that pull procurement data, attribute to ingredients/suppliers, and retain audit trails. Prioritize your top-impact suppliers; request LCA-based factors, reduction targets, and packaging/logistics transparency.
5) Prepare for assurance early
Document assumptions, sources, versions, and controls. Your verification will go faster, whether you report in 2025 or after the postponement.
• Treating Scope 3 as non-mandatory. It’s materiality-based under ESRS—but in food, it’s usually material. Plan for it.
• Over-relying on spend-based proxies. Use activity/quantity-based data where possible; disclose methods clearly.
• Ignoring the proposal status. Communicate clearly that scope and timelines reflect Omnibus proposals pending adoption.
The earlier you start collecting, cleaning, and structuring your data, the smoother assurance becomes later.
Klimato simplifies CSRD preparation through:
• GHG Protocol-aligned calculations for Scopes 1, 2, and 3
• Ingredient-level data and country-specific factors
• ESRS-ready outputs to streamline E1 climate disclosures and assurance prep
• Supplier engagement workflows and evidence trails
Learn how Klimato’s Environmental Reports make CSRD reporting simple, reliable, and audit-ready.
Q: Does CSRD apply to all food businesses now?
A: No. As of now, companies with more than 500 employees, >€50M turnover, or >€25M balance sheet need to report. Large companies and listed SMEs will need to report in a couple of years, unless the Omnibus proposal changes the scope of CSRD, which will reduce the number of companies that need to report. Smaller companies may be out of scope—pending adoption—but will still be asked for reliable data by in-scope customers.
Q: Is Scope 3 mandatory?
A: ESRS E1 requires Scope 3 when material. In food, Scope 3 is typically material due to agriculture, packaging, logistics, and waste.
Q: What’s new in 2025?
A: Wave 1 reports on FY2024 in 2025 (unchanged). Later waves are postponed by ~2 years (e.g., large undertakings report FY2027 in 2028).
Q: We’re not reporting until 2028/2029. Should we wait?
A: No. You’ll still need verifiable Scope 3 data for customers and tenders; building systems and supplier engagement now reduces assurance friction later.
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