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EU Commission proposes amendments to the CSRD, CSDDD, and EU Taxonomy, and introduces its Clean Industrial Deal to enhance the Union’s competitiveness.In brief

Today (26 February 2025), the European Commission published multiple policy documents and legislative proposals, following through on its commitment to improve the EU’s competitiveness under the European Commission’s Competitiveness Compass published on 29 January 2025.


Key takeaways

The following proposals are likely to be particularly relevant for businesses:

  • The “Simplification Omnibus package“, which proposes amendments to the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Taxonomy Regulation (“EU Taxonomy“). Key proposals include the postponement of reporting obligations for CSRD and delayed implementation of CSDDD, reduction in applicability scope for CSRD and far-reaching amendments to the obligations under the CSDDD. Please see a detailed analysis of the proposal here
  • The “Clean Industrial Deal” seeks to promote EU industrial competitiveness, particularly in energy-intensive sectors, whilst maintaining the goal of achieving climate Net-Zero by 2050 – an important part of the package is a Commission proposal that the EU commits to a 90% GHG by 2040. The key actions of the Clean Industrial Deal include revision of the Public Procurement Directive offering protection for EU manufacturers, a significant redesign of the Carbon Border Adjustment Mechanism, the establishment of an ‘Industrial Decarbonisation Bank’ providing funding for industrial decarbonisation (with a funding target of EUR 100 billion, and a first EUR 1 billion pilot auction already set for 2025) and an ‘Affordable Energy Act’ (introducing a number of changes to the functioning of the EU’s energy markets, a strategy to reduce taxes on electricity, default guarantees for long-term power purchase agreements and changes to grid planning). Please see a detailed analysis of the communication here.
  • The announcement of an important reform of the State aid rules, aimed at simplifying and making clearer the rules, especially those regarding aid to assist industry to decarbonise. This will be published by the Commission in Q2 2025.

For more information, please contact our team of experts.

Author

Eva-Maria is a partner in our Austrian corporate / M&A group and a member of our global sustainability practice. She acts as global lead sustainability partner for our financial institutions industry group, heads Baker McKenzie's capital markets practice in Austria and is a member of our EMEA steering committee for capital markets. Eva-Maria is a dual-qualified lawyer, admitted to practice in Austria and New York. Prior to joining Baker McKenzie's Vienna office in 2008, Eva-Maria worked in the New York, Paris and Frankfurt offices of a well-known US law firm.

Author

Graham Stuart is a partner in Baker McKenzie's London office specialising in product regulation and environmental, health and safety law.

Author

Anahita Thoms heads Baker McKenzie's International Trade Practice in Germany and is a member of our EMEA Steering Committee for Compliance & Investigations. Anahita is Global Lead Sustainability Partner for our Industrials, Manufacturing and Transportation Industry Group. She serves as an Advisory Board Member in profit and non-profit organizations, such as Atlantik-Brücke, and is an elected National Committee Member at UNICEF Germany. She has served for three consecutive terms as the ABA Co-chair of the Export Controls and Economic Sanctions Committee and as the ABA Vice-Chair of the International Human Rights Committee. Anahita has also been an Advisory Board Member (Beirätin) of the Sustainable Finance Advisory Council of the German Government.

Anahita has won various accolades for her work, including 100 Most Influential Women in German Business (manager magazin), Top Lawyer (Wirtschaftswoche), Winner of the Strive Awards in the category Sustainability, Pioneer in the area of sustainability (Juve), International Trade Lawyer of the Year (Germany) 2020 ILO Client Choice Awards, Young Global Leader of the World Economic Forum, Capital 40 under 40, International Trade Lawyer of the Year (New York) 2016 ILO Client Choice Awards. In 2023, Handelsblatt recognized her as one of Germany’s Dealmaker and “most sought after advisors of the country” in the field of sustainability.

Author

Christopher Jones is a Principal in the European Competition Law Practice Group in the Brussels office. He joined Baker McKenzie in 2018.

Christopher's career has spanned more than 30 years at the European Commission, focusing on energy policy and competition policy.

During the last two decades, Christopher held a wide range of key energy posts including Director for Renewable Energy, Energy research and Energy Efficiency, Deputy Head of Cabinet for the Energy Commissioner and Deputy Director General for Energy.

He has been at the forefront of many major key energy and competition law decisions and innovations. He played a key role in the evolution of EU competition law towards the more economic and market based instrument it is today, and was instrumental in the successful implementation of EU merger control. He was the central EU official in opening up energy markets to competition as well as developing and implementing the core of the EU's energy policy as it is today; driving the '20-20-20' renewables and energy efficiency decarbonisation agendas, and setting the gas strategy and research policies.

Christopher is also an expert on competition policy, having spent 11 years in the field including responsibility for antitrust and mergers in the Cabinet of the Energy Commissioner, and as personal Policy Assistant to two Directors' General.

He is a leading academic in the competition and energy areas, as a part-time Professor at the European University Institute, editing and co-authoring a number of standard text books on Competition Law and Energy Markets, the Internal Energy Market, and EU Renewable Law and Policy, as well as books on merger control and the standard competition law reference work, the EU Competition Law Handbook.

Author

Dr. Alexander Ehrle is a member and senior associate of the Firm‘s Sustainability & International Trade Practice in Baker McKenzie's Berlin and Brussels offices. Alexander is admitted to practice in Germany and New York.
Alexander advises clients on the international, European and public law governing international trade and geopolitics. Alexander handles the FDI and FSR applications and clearances in M&A transactions in the EU, Germany and globally and has been recognized for his work as one of 40 under 40 lawyers worldwide for foreign investment control by the Global Competition Review. His practice encompasses advising on international sanctions and export controls at all stages of investigations, audits and court proceedings. Alexander is also an expert in ESG legislation and advises client on the compliance with the CSDDD, the LkSG, the CSRD and ESRS, and other EU Green Deal Regulations, such as the EU Deforestation Regulation, the EU Forced Labor Regulation and CBAM. He advocates for a diligent approach to ESG regulation and provides his expertise to an international audience as co-chair convening the Business & Human Rights Committee of the American Bar Association’s International Law Section.
Alexander studied law at the Universities of Heidelberg, Montpellier (France), Mainz, Munich and New York (NYU) specializing in Public International and European Law. He worked as advisor and member of a delegation of a developing country at the United Nations before qualifying for the German bar. He qualified for the German bar, working with the German Ministry of Foreign Affairs’ Middle East Department in Berlin and the German embassy in Tokyo as well as with international law firms in Frankfurt, Berlin and Milan.
Alexander has been seconded to and worked with a major company in the optical industrial and manufacturing technology sector.

Author

Gabrielle is a Senior Associate in the London office with over 15 years of experience (in the UK, EU and Brazil) supporting global businesses and non-profit organisations with legal, strategy, disputes, risk management and governance advice, in particular for tax and ESG matters.

Author

Nina is an associate in the EU Competition and Regulatory Affairs Practice Group in the Brussels office. She joined Baker McKenzie in October 2024. Before joining Baker McKenzie, Nina worked in an American law firm in Brussels, where she assisted clients on sustainability-related matters and circular economy legislation. Before moving to Belgium, Nina was associated with a renowned Polish law firm, Wardyński & Partners, where she advised on environmental and regulatory aspects of mergers and acquisitions. She also completed traineeship at the European Commission's Directorate General for the Environment.

Author

Maritje is a legal consultant in the European Competition and Regulatory Affairs Practice Group in the Brussels office. She joined Baker McKenzie in March 2023.