If you are based in Germany, France, Netherlands, Austria, or Switzerland, there is nothing to do yet. Whatever you legally had to do yesterday and the day before, you have to do today. And this is the most critical detail that commentators often miss out on. EU policy is a laborious process. CSRD took over two years to enact - scroll through the timeline to see for yourself. Some countries have still not transposed it.
At the end of the day, it is your national government that ultimately decides what happens on the ground, how quickly policy changes are adopted and whether they are adopted in full. At this stage, it is equally important to pay attention to the European Parliament and the debate at your national government level. For businesses, this means the government where their HQ is based or the location that centralises and discloses financial reports at a group level.
A quick reminder: the EU has seen this before
As a reminder about Omnibus processes, in 2022, the EU Parliament rejected a resolution to dilute CSRD requirements.
Figure 1. EU Parliament rejects calls for a resolution to reduce CSRD requirements and increase employee threshold by 359 votes against and 261 votes for
The negotiation for or against can be rapid (estimated 3-6 months) but can also lead to nothing and take years. For example, in 2013, the EU proposed three omnibus packages, which, after years of debate, led to their withdrawal and an alternative legislative approach.
What should I do as a business leader?
Follow your national legislation and use this time to prepare. The Omnibus kept some of the critical structural elements of the ESRS—double materiality and mandatory data points. In the background, EFRAG, the technical committee that drafted the ESRS data points, has likely already started work on figuring out what the ‘simplification of ESRS data points’ looks like in practice.
However, sustainability and climate targets are here to stay. CSRD is already incredibly useful in showing how companies achieve those targets transparently and providing a level playing field. This also helps lenders, banks, and all actors across the supply chain understand what happens on the ground rather than having to read through or use AI to interpret well-narrated stories.
Financial stakeholders still require climate disclosures to understand where to increase capital expenditure lending and which sectors to prioritise. Policies like CSRD help us collectively focus efforts on action rather than words. They also help build meaningful benchmarks so companies can compare performance between their corporate competitors and even on a product level.
Ultimately, this granular decision-making is needed to balance carbon and cost efficiency.
Decarbonisation is a necessary investment in future competitiveness
Companies in each sector still need to decarbonise, which is enforced via sector-specific policies (Ecodesign for products is a great example). There is no signal from the Commission that sector-specific policies are going backwards. Whether you started your CSRD journey or are awaiting further details, one thing is for sure - your business will need to reduce its emissions in any case!
Whether the EU requires you to transparently tell the market and your customers how you are doing in a highly structured way is effectively a matter of time. So let us not miss the forest from the trees. CSRD is here to stay in the long run, and perhaps if Omnibus had been the starting point from the outset, we would not have felt so uncertain. Alas, this is the reality of policy and democracy: messy, uncertain and contentious in the best times.
Apart from keeping an eye on our pages as we post updates, following the national debate in your own Parliament is the best signal for what is likely to happen in your country. Countries decide policy, but ultimately, companies and citizens bear the brunt and decide how rapidly, sensibly and practically, we can decarbonise the economy.
Business and government leaders must recognise that climate action is not a financial burden but an investment in stability, resilience, and future prosperity. The economic case is clear. CSRD is not just about reporting, but about helping EU businesses gain visibility on their materiality and be better prepared for a future shaped by climate disruption and systemic instability.
- Lubomila Jordanova, CEO and Co-founder, Plan A.
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