On December 16, 2025, The European Parliament approved the simplification package called Omnibus[1], which raises the financial and employment thresholds for the CSRD (Corporate Sustainability Reporting Directive) and CSDDD (Corporate Sustainability Due Diligence Directive). The new thresholds stand at 1000 employees and 450 million euros in turnover, up from the previous levels of 500 or 250 employees. Furthermore, full application of CSDDD for the largest entities has been postponed until mid-2028. As a result, it is estimated that even several thousand companies within the European Union will avoid the obligation of direct reporting over the next two years. The Omnibus package was created in response to business appeals to reduce administrative burdens and strengthen the competitiveness of European companies. The trilogue between the European Parliament, the European Commission, and the Council of the European Union ended with an agreement designed to provide short-term cost relief for enterprises. However, risks arise in supply chain transparency, as large corporations will still require data from smaller suppliers who will no longer be formally obliged to report, potentially leading to informal ‘backdoor’ reporting requirements.
European Parliament Approves Omnibus Package
In Poland, on December 22, loan agreements from the National Reconstruction Plan (KPO)[3] amounting to 475.32 million zlotys were signed to finance the construction of photovoltaic installations. New installations are expected to reach nearly 250 megawatts peak (MWp), with the first electric output from these farms to be fed into the grid by the end of 2027 at the latest. Investments focus on post-industrial areas, responding to social protests against locating farms on high-quality agricultural land. The agreements were signed between renewable energy operators and investors and institutions implementing the KPO in Poland. This investment boost signals a revival for contracting companies in the first half of 2026 and sets a new locational standard for large photovoltaic farms in the country.
Investments in Photovoltaics from the National Reconstruction Plan
In mid-December 2025, Polish Power Grid Company (PSE) presented the assumptions of its new energy network development strategy[4]. The strategy anticipates that by 2035, the average share of renewable energy sources (RES) in electricity production will reach 60%, sometimes even up to 100%. By 2040, the plan is to achieve 110 gigawatts in RES capacity and 24 gigawatts in energy storage. Investments in infrastructure are expected to reach around 75 billion zlotys over the next decade. PSE’s strategy aligns with the national energy policy. Practically, this means a massive construction site in the Polish energy sector, pressure on the capacity market and system services. Coal power plants will operate less frequently but remain as reserves, necessitating new financing mechanisms like 2.0.
PSE Strategy for Energy Network Development
In December 2025, vocal legal disputes over greenwashing intensified. The Client. Earth Poland Foundation continues a lawsuit against Nestlé Poland concerning the Nałęczowianka brand, while in the United States, a class-action suit began against Procter & Gamble over the Charmin brand. These legal disputes challenge marketing slogans such as ‘100% recycled’ or ‘sustainable sources’, questioned in light of actual technological capabilities. Regarding Nestlé, the dispute concerns claims that plastic bottles are eco-friendly and fully circular. The lawsuit was filed in September 2025, and December analyses indicate the case may set a precedent defining standards for 2026. Italy imposed a 1 million euro fine on Shein for misleading environmental claims. Organizations like Client. Earth and the law firm Hagens Berman are involved in these cases. This signals the end of the era of soft PR, forcing marketing departments to consult lawyers on every ecological claim. In Poland, the first rulings defining the boundaries of greenwashing in the FMCG sector are expected in 2026.
Wave of Greenwashing Lawsuits Against Major Companies
In mid-December 2025, The European Union officially launched the RESourceEU initiative[18] aimed at supporting raw material security. This initiative is part of implementing the Critical Raw Materials Act (CRMA) and seeks to reduce the EU’s dependence on raw material imports from China. The main goal is to increase domestic extraction and recycling of critical raw materials, targeting a 25% recycling rate by 2030. Currently, the recycling rate for many rare earth metals causes losses of about 100 billion dollars, marking the most expensive half-year in history. From January to September 2025, China suffered direct losses of 30.5 billion dollars. Insurers participating in the initiative collaborate with governments through reinsurance to cover insurance gaps. In 2026, a sharp rise in insurance premiums for companies is expected, known as a hard market. This may lead to insurers withdrawing from certain regions, a trend already observed in the United States.
RESourceEU Initiative for Raw Material Security
It is worth noting some weaker signals worthy of attention. Poland’s EU presidency in the first half of 2025 ended with a strong focus on energy security, which could influence discussions on the ETS2 system in 2026. In the transport sector, December 2025 forecasts indicate that the fuel cell electric vehicle (FCEV) market could reach 45 billion dollars[5] by 2033, despite current skepticism in the automotive industry. Hydrogen technology is shifting towards heavy transport. The battery energy storage systems (BESS) market is expected to hit 100 billion dollars by 2033, signaling new vast market opportunities for Polish companies like Tele-Fonika and cable and accessory manufacturers.
Other Signals and Outlooks for Poland
By the end of 2025, the situation for Polish companies is clear: regulatory easing of requirements in the EU thanks to the Omnibus package is only temporary[2], while market and legal pressure regarding greenwashing and supply chain transparency increases. In January 2026, it will be crucial to verify whether companies meet the new, higher CSRD thresholds, granting them additional time for adjustment. Concurrently, preparation for participation in energy projects worth 75 billion zlotys announced by Polish Power Grid Company will be important. Funds from the National Reconstruction Plan for renewable energy are already reaching investors, and the first quarter of 2026 promises tenders for the execution of photovoltaic farms and energy storage projects.