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Twelve Omnibus Packages Later the Terrible Ten Remain in Place

Eindhoven: By June 2026 the Commission had tabled twelve omnibus simplification proposals, which it calculates – together with other measures – as worth around EUR 18 billion a year in reduced administrative burden. The packages have moved through corporate sustainability reporting, due diligence, agriculture, digitalisation, small mid-cap companies, defence procurement and chemicals legislation. More are promised. It is, by volume, the most concentrated deregulatory exercise the Union has attempted.

The number invites scrutiny, because administrative burden savings are calculated rather than observed. The standard cost model estimates how long a compliance task takes, multiplies by a wage rate and by the number of firms affected, and reports the product. It is a reasonable way to compare proposals and a poor way to predict outcomes, because it assumes firms were performing the task as specified, that they stop performing it when the obligation is removed, and that no cost migrates elsewhere. A company that drops a sustainability report because the threshold moved may still produce one because its lender asks for it.

More telling is what the simplification agenda has not touched. The Single Market Strategy identifies the ‘Terrible Ten’ – the barriers the Commission itself names as the most significant obstacles for businesses, workers and citizens moving across borders. These are not reporting obligations. They are divergent national rules on posting workers, fragmented product requirements applied through national certification, territorial supply constraints, retail establishment restrictions, professional qualification recognition, and the accumulated administrative practice that makes operating in a second member state a distinct project rather than an extension of the first. None of them yields to an omnibus, because the obligations generating them are national.

That is the structural asymmetry in the exercise. The Commission can propose amendments to EU legislation and does, at pace. It cannot amend the twenty-seven national implementations that sit on top, and gold-plating in transposition accounts for a substantial share of what firms actually experience as European regulation. A directive simplified in Brussels arrives at a Dutch or Italian firm through a national transposition that may be simplified later, differently, or not at all.

The Commission’s alternative route around the asymmetry is the 28th regime – the EU Inc. proposal tabled on 18 March 2026, creating a European corporate form alongside the existing twenty-seven, with incorporation targeted at 48 hours and immediate capacity to operate across the single market. Paired with the European Business Wallet proposed the previous November, which public bodies must accept for core functions, it offers companies a way to opt out of national fragmentation rather than waiting for it to be dismantled.

This is an elegant answer to an intractable problem and a significant constitutional move, which is why the choice of legal instrument is contested. A regulation requiring qualified majority is faster and forecloses national vetoes; a directive, or a regulation on a legal basis requiring unanimity, gives member states the ability to shape or block it. The difference is not procedural housekeeping. It determines whether the Union can create a parallel company law without the consent of the states whose company law it is paralleling.

The annual single market and competitiveness report calls for joint action in the face of what it describes as unprecedented challenges, which is the language institutions use when the instruments they control are not sufficient to the problem they have identified. Twelve omnibus packages have removed real costs. The barriers that make a firm in Eindhoven treat Belgium as an export market rather than a neighbouring region are, for now, where they were.