In light of these findings, NGOs warn that the Commission must end the use of undemocratic processes to weaken safeguards, notably through the ongoing omnibus simplification packages.

The Ombudswoman Teresa Anjinho today found that the EU Commission’s handling of Omnibus I on corporate sustainability rules and the 2024 “simplification” of the Common Agricultural Policy (CAP) violated fundamental principles of good administration, including transparent, inclusive, and evidence-based law-making.

The decision follows several complaints brought by ClientEarth, Anti-Slavery International, BirdLife Europe and Central Asia, Clean Clothes Campaign, European Coalition for Corporate Justice, Friends of the Earth Europe, Global Witness, Notre Affaire À Tous, and T&E (Transport & Environment) who raised alarm over the Commission’s undemocratic and opaque processes that prioritized corporate interests over public and environmental welfare.

ClientEarth Head of Brussels Anaïs Berthier said: “The Ombudswoman makes clear that the EU Commission cannot roll back environmental standards with complete impunity and that decisions must be backed up by science and objective facts. This is not the Wild West – the EU institutions must follow basic democratic principles.”

“At a time when EU political leaders are under pressure from foreign powers and corporate lobbies to dismantle the protections that ensure we – and our children – can live healthy lives in a safe environment, this decision is a vital reminder that the Commission is not above the law. It confirms that it must comply with the Better Regulation Guidelines, the EU Climate Law and carry out proper assessments. Civil society and the progressive part of the industry must not be sidelined – they need to be given the space to contribute meaningfully.” 

Omnibus I under scrutiny

Earlier this year, a coalition of 8 NGOs filed a complaint to the EU watchdog over the process behind the adoption of the first Omnibus package, which sought to weaken key corporate accountability laws, including the corporate sustainability due diligence directive (CSDDD).

The Ombudswoman’s investigation led to sharp criticism of the Commission for:

• Skipping the required impact assessment to weaken the law, and claiming that ‘urgency’ made bypassing these evaluations justifiable.
• Limiting stakeholder consultation required by the EU Treaties, holding meetings dominated by industry representatives while effectively excluding most civil society actors.
• Failing to provide evidence that they had carried out the climate-consistency assessment mandated by the European Climate Law.

ClientEarth, Anti-Slavery International, Clean Clothes Campaign, European Coalition for Corporate Justice, Friends of the Earth Europe, Global Witness, Notre Affaire À Tous, and T&E (Transport & Environment) said: “Today’s decision is a serious blow for the Omnibus. The Commission failed to meet the standards of transparency, evidence, and consultation that EU lawmaking requires. Adopting a law based on such a flawed basis would raise serious doubt about its legal soundness. Policy makers must now ensure that a full impact assessment is completed and that any political agreement is grounded in evidence and in line with EU climate goals. If this cannot be secured, the Commission should withdraw its proposal. This applies not only to the first Omnibus but also to all other proposed or planned packages.”

CAP rollbacks also criticised

In 2024, ClientEarth and BirdLife Europe and Central Asia raised the alarm about the Commission’s bypassing of democratic process, to usher through a weakening of key environmental requirements in the Common Agricultural Policy (CAP) – amidst farmers’ protests.

The Ombudswoman also found that the Commission’s ‘urgent’ amendments were rushed and lacked proper impact assessment or scientific justification.

She found “questionable” that the consultation was limited to four farming unions and held behind closed doors – ignoring broader public and civil society input – and dismissed the view of other members of the public. The Commission even argued that environmental NGOs would not be concerned by CAP amendments and therefore did not need to be consulted, a claim the Ombudswoman firmly rejected. In reality, these organisations should have been part of the process from the start.

The NGOs said: “The Ombudswoman confirms what we have said from the start: the Commission bypassed fundamental democratic processes to water down environmental protections under the CAP, using “urgency” as an excuse.

The Commission cannot sidestep democracy just to feed the interests of the biggest players in the farmers’ lobby. No one should be above the law. Policymakers must ensure fully transparent, evidence-based negotiations that include all stakeholders, including environmental NGOs.

With many more upcoming omnibus packages that will impact environmental protection across the board, the Commission received a clear message: laws cannot be weakened in this way, and it must immediately stop watering down environmental protection through rushed, non-democratic processes.”

ENDS

Background information – general:

What can the Ombudsman do? While influential, the European Ombudsman cannot enforce decisions but can issue recommendations. The Commission is revising its  Better Regulation Guidelines and implementing these recommendations is crucial to ensure  transparency, inclusivity and accountability of the lawmaking process, not dilute                        it.

Regarding the Omnibus complaint:

On 18 April 2025, ClientEarth and coalition partners submitted a formal complaint to the European Ombudsman, citing failures in the Commission’s preparation of the Omnibus proposal, specifically, the lack of a comprehensive impact assessment and inadequate public consultation.

The Omnibus proposal seeks to weaken major EU sustainability frameworks, including the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Taxonomy Regulation. NGOs warn that the proposal risks undermining years of progress on corporate accountability and environmental protection, while also eroding public trust in the EU’s democratic processes.

In June 2025, ClientEarth lawyers cautioned that legal experts have identified strong grounds for challenges to the EU Commission’s Omnibus proposal if passed into a law. 

In early November, the European Parliament endorsed the simplification package of Omnibus I, significantly weakening due diligence and reporting obligations under the Corporate Sustainability Due Diligence Directive (CSDDD). With support from the far right, a majority led by the conservative European People’s Party (EPP) scrapped CSDDD requirements for companies to develop credible climate transition plans and endorsed removing an EU-wide civil liability regime.

Regarding the CAP complaint:

• The CAP “simplification” amendments were proposed in March 2024, following farmers’ protests and a behind closed doors consultation of only four farming unions The resulting proposal even went against the wishes of two of these four unions.
• In response a group of 16 NGOs wrote to Commission President Ursula von der Leyen to ask for the proposal to be withdrawn – but without success. At the time, ClientEarth’s lawyers commented, termed the lightning-speed process that led to the revision “blatantly incompatible with EU law”. 
• ClientEarth and BirdLife Europe and Central Asia then submitted their original complaint to the Ombudsman in July 2024 – story here, and complaint text here.
• The European Environment Agency warned against reflex lawmaking in its 2022 report (updated in April 2023), confirming that landmark agri-environmental policies ‘should not be undermined by short-sighted responses to rising food prices and fears of global food shortages resulting from the invasion of Ukraine.’
• ClientEarth and the CAP: In 2023, ClientEarth also partnered with Collectif Nourrir to challenge the EU Commission’s approval of France’s strategic plan under the CAP, arguing that it fell far short of the Policy’s environmental requirements. In October 2025, the CJEU ruled that the European Commission was wrong to approve it, forcing the Commission to rethink their approval of the plan.

A coalition of eight NGOs lodged the formal complaint with the European Ombudsman regarding the European Commission’s Omnibus proposal: ClientEarth, Anti-Slavery International, Clean Clothes Campaign, European Coalition for Corporate Justice (ECCJ), Friends of the Earth Europe, Global Witness, Notre Affaire À Tous and T&E (Transport & Environment).

The complaint to the European Ombudsman regarding the EU Commission’s amendments to the Common Agricultural Policy was brought by ClientEarth and BirdLife Europe and Central Asia

Photo: Corn Crake –Yves Adams