From Harmonization to Fragmentation: The Impact of Omnibus I on Climate Transition Planning in Spain

Abstract

This article examines whether Omnibus I, adopted to simplify EU corporate sustainability law and enhance competitiveness, may instead contribute to a more complex legal framework for climate transition planning. It contrasts Omnibus I’s retreat from the EU-level obligation to adopt and put into effect climate transition plans under the Corporate Sustainability Due Diligence Directive (CS3D) with Spain’s Royal Decree 214/2025, which requires certain companies to calculate their carbon footprint, prepare five-year greenhouse gas emissions reduction plans, and publish both. Omnibus I has implied returning EU law largely to a reporting-based model centred on the obligations to disclose information on transition plans where such plans exist under the Corporate Sustainability Reporting Directive and the European Sustainability Reporting Standards. Through the Spanish case study, this article shows that national regimes may preserve part of the substantive climate-planning ambition removed from the CS3D, although with narrower emissions coverage, methodological uncertainty, and indirect enforcement. It argues that Omnibus I may therefore undermine its own harmonization and simplification objectives by enabling divergent national climate planning regimes within the internal market.