The EU Omnibus Package On Sustainability Disclosure

The EU Omnibus Package On Sustainability Disclosure


In short, to support your reporting planning under CSRD, we advise that:

EU listed large companies – maintain business as usual

If you reported against CSRD in FY2024, and the Non-Financial Reporting Directive (NFRD) before that, there are no modifys to thresholds or timelines. While simplification of the ESRS is underway, there may limited opportunity to respond to the modifys in your next report. Focus on aligning with its intent by developing strategies to manage your Impacts, Risks, and Opportunities (IROs) and that you are clearly reporting on how they align with the actions you’re taking, the metrics and KPIs you’re applying, and your performance.

Find out more about the proposed modifys to the ESRS here

Businesses due to report in FY2025 – do not press paapply on your planned actions

For companies with a two-year delay, apply this time to prepare. If you haven’t already, start your double materiality assessment, applying the draft ESRS revisions as a guide. This will give you time to collect data, close gaps, and shape an integrated sustainability strategy ahead of the FY2027 deadline.

If you’ve already finalised your Double Materiality Assessment, launch preparing for a gap analysis focapplyd on at least three core ESRS: E1 (Climate), S1 (Own Workforce), and G1 (Business Conduct). Analysis of existing reports from Wave 1 companies reveals that these were universally adopted, creating them a logical and low-risk starting point. Prioritising mandatory quantitative disclosures within these ESRS will support maintain momentum without overcomplicating early-stage reporting efforts.

See our recent webinar recording for more information >

SMEs – take a stakeholder-focapplyd approach

Even if requirements shift, early action has benefits. Conducting a Double Materiality Assessment will support meet investor expectations, improve your corporate reputation, support your value chain relationships, and identify and benefit from better risk management and cost efficiencies ahead of potential regulatory modifys.



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