What will change
How much resources we/they should put into the sustainability reporting and the ESG department as a result of the Omnibus.
Understanding the changes
Whether we even will need to report
Leadership is not fully aware of the changes
Concerned about EU taxonomy transposition in a voluntary framework
What we do right now
What is the best forward to manage the risk of non compliance with the delay and the timeline of original and omnibus? How do you justify the roi for continuing at full scope or original csrd? What are the benefits?
What will happen in Spain as the previous reporting national law ( transposing NFRD) was more ambitious than the Directive and companies over 250 employees have being reporting according to it for 5 years? Will Spanish companies between 250 and 1000 employees stop reporting?
Limited assurance standard adoption
Uncertainity
We are waiting to see how other SMEs react.
As we are a publicly listed XL company, Omnibus proposal do not change much our core commitments. Just the CS3D are subject of major changes (huge relief as we are still laying down foundations for it), but this is to be discussed further on our quarterly meeting.
Disappointed about the lower ambition of EU ...
They have taken the proposal and the raised tresholds already as a done deal and are quite relieved to be released from the reporting burden. It is unclear if loosing the driver of obligatory reporting will result in an overall reduced commitment to ESG and limiting resources to this cause.
investments that we were looking for ERP solutions to digitise and automate data required for reporting will be impacted due to reduced urgency
Timelines and scope clarity for mandatory reporting
Unclarity about our scope
what will be the impact on company decisions
How should we proceed (in line with ESRS, VSME, or GRI)?
What reporting disclosures that gives us actual value
What is the expected Tier 1 and Tier 2-Changes timeline?
Nothing yet. We are not subjected to CSRD, so we work with sustainability as until now: inspired by CSRD and VSME. They do not pay that much attention (yet) to the law as we are not part of it. I will be the one to inform about it, and I will reccomend that we continue, and keep ESG and a report (VSME-inspired) priority. But of cause interesting to see if a report will still have a value after this.
Concerns about: which data will still be mandatory to report (what about narrative data), how will the limited assurance audit be executed (no clear view on our auditors approach), what about the DMA that we already executed (will our approach still be valid in 2 years).
What is the impact of the omnibus on investors and customers?
Our leadership has raised several concerns regarding the CSRD/Omnibus directive. Firstly, there is significant uncertainty surrounding the regulatory environment. The evolving nature of the regulations and the lack of clear guidelines make it challenging to ensure compliance and align our reporting processes effectively.
Secondly, there is confusion about why the European Commission funded EFRAG for several years, only to lead to excessive bureaucracy and a disconnect between reporting requirements and actual business operations. This has created additional administrative burdens without providing tangible benefits to business strategy and performance.
Lastly, despite these challenges, the CSRD directive remains in force, leaving us uncertain about the next steps. We are navigating a situation where compliance is mandatory, but the future direction of reporting requirements and expectations remains unclear.
Does it make sense to wait for the proposal to be accepted or should we change our reporting strategy now?
Uncertainty
Are there risk for the job market for sustainability specialists and managers? Is the simplification the real reason behind Omnibus or it’s just about to stop sustainability reporting or significantly reduce it in the long future
They just asked what we can expect and what we're going to do (we're going to continue reporting as we were doing for July/23 to July/24) and then, when we're sure if they're going to postpone or if there's going to be any change, then we'll make decisions internally about how we want to proceed (we have less than 1000 employees, for example).
Clarity on timing and thresholds
Uncertainty -lack of formal communication from our business partners on the effect on us.
Uncertainty over which subsidiaries will be included.
Should we postpone the DMA and gap assessments?
N
difficult to scope
Concerns on the uncertainity about when we will have a final decision. How to proceed?
Uncertainty if the proposal will change
As of now, not much
Nn
N/a
When will the proposal be finalized? Since the CSRD is not implemented in Dutch law it’s not considered a major concern or risk at the moment.
CSRD is already in our national laws. How much time it will take EU to decide wether the CSRD is going to change and does national law enforcment act quickly. It is frustrating to wait and if you stop working, might be too late IF the Ombibus doesnt change the reporting direktive.
What and when will it be applicable.
How do we continue to use our aquired knowledge from CSRD and at the same time minimise the time needed for reporting.
Clarity about national response to omnibus
We view it as a betrayal of the vocational spirit of all companies that, like Benefit Corporations, practice and advocate for sustainability every day.
Frustration with being jerked around by a smaller market for our business.
Given that existing CSRD is transposed into national law, what happens in the interim?
Uncertainty around timelines of implementation and scope of reporting
Nothing yet. We are waiting to know more. We will continue in a similar way, even if we are not in scope.
