EU Omnibus proposal: Different groups, opportunities and considerations

We also list the developments and opportunities that we see in the field of assurance in sustainability information and reporting.

Listed companies or companies of public interest with more (or less) than 1,000 employees  

Scenarios and considerations of this group  

• This group is currently publishing its first CSRD reports, having learnt lessons for both strategy and reporting in the process and receiving responses from stakeholders. 
• The proposed employee limit is going to determine whether CSRD reporting remains mandatory. This will apply to most. There may also be a simplified reporting standard.  
• For this group, it is important that after an intensive period of preparing a report, there is again space to continue working on their own sustainability strategy, impact and sustainability plans to include in the next reports.  

Recommendations for strategy and reporting  

• Use the first round of reporting as a springboard for further improvement. 
• A review of lessons learned during the preparation of the first CSRD report can help further improve the reporting process and content. What went well? What could be improved? Are stakeholders satisfied? What is necessary? What is ‘nice to have’? 
• Continue to prepare future reports in line with CSRD, while continuing to follow the development of the reporting standard.  
• The core remains making progress from one's sustainability ambitions, further developing policy or transition plans, implementing action plans, measuring impact, or developing objectives for resilience and a future-proof strategy. CSRD offers valuable tools for this purpose.  
• Regarding the chain (risks), meaningful steps can be taken with due diligence in preparation for CSDD and getting a grip on the chain.  

Assurance developments and recommendations  

• Reporting with limited assurance will be maintained. Discuss additions or a change in the reporting approach, compared to last year, with the auditor. Determine the ‘milestones’ together and agree on a timeline. 

Large companies with more than 1,000 employees  

Scenarios and considerations of this group  

• This group has recently been preparing for a 2025 CSRD report and has taken the sustainability strategy further. Stakeholders such as financiers, customers, clients, and employees expect sustainability information (on impact, targets, efforts, and risks) from this group. 
• With the proposed postponement, this group wonders whether a CSRD report may not have to be ready for the first time until 2027. In addition, there may be a simplified reporting standard.  
• This group would like to continue using the preparatory work that has already been done and could make effective use of extra time to take important steps that contribute to its sustainability strategy and still be ready for reporting.  

Strategy and reporting recommendations  

• Use the extra time to get a head start. 
• CSRD has already set the standard and valuable preparation has been done. Therefore, keep taking steps towards a sustainability report in line with CSRD for 2025. The delay is not yet certain.  
• If postponed, work can be done on the dual materiality analysis (update or complete) for valuable insights on risks and opportunities. Taking sustainability plans further and collecting data with less pressure from compliance.  
• The core remains making progress on one's sustainability ambition, further developing policies or transition plans, implementing action plans, measuring impact, or developing objectives for resilience and a future-proof strategy. CSRD offers valuable tools for this, and more time may come. 
• Regarding the chain (risks), meaningful steps can be taken with due diligence in preparation for CSDDD and grip on the chain, especially if more preparation time is offered.  
• In addition, part of the effort could be shifted to preparing for other developments such as the EU deforestation regulation (EUDR) or Extended Producer Responsibility (EPR). 

Assurance developments and recommendations  

Assurance increases the quality and reliability of reporting. 

• Reporting with limited assurance may be delayed. Stakeholders and supply chain partners, commercial partners, and covenants (such as banks, investors, customers, or sector agreements) may request reporting on specific components or KPIs. If the CSRD is delayed, there is still an opportunity to apply assurance on these components (e.g. the CO2 footprint or the transition plan) so that stakeholders have reliable data for their decision-making. 
• It remains wise to coordinate with the auditor on the reporting approach regardless of any postponement. To make timely adjustments to the CSRD process and review the preparation together in time (e.g. the double materiality analysis). 

Large companies with fewer than 1,000 employees and listed SMEs with fewer than 1,000 employees  

Scenarios and considerations of this group  

• Recently, this group has been preparing for a CSRD report for 2025 or later and moving the sustainability strategy forward. Stakeholders such as financiers, customers, clients, and employees still expect sustainability information (on impact, targets, efforts, and risks) from this group. 
• In the proposed change, this group would potentially no longer have to prepare a CSRD report. There is a voluntary reporting standard available called Voluntary Small Medium Enterprise - European Sustainability Reporting Standard (VSME-ESRS) that this group will look at. Because of their conviction and ambition, or because the information needs of stakeholders on sustainability performance and policy do not change. Or because, for instance, industry peers are also starting to use it.  
• This group is keen to make use of the preparatory work that has already been done and can use the time to take steps at their own pace that contribute to the sustainability strategy and moving plans forward. 

Recommendations for strategy and reporting  

• Take the initiative and become a leader. 
• Reporting (internal and external) is valuable even without obligation. To inform stakeholders and users, to distinguish from competitors, and to keep track of their own performance. This can still be done by continuing to follow the ESRS, especially if market players also continue to do so. 
• VSME will be able to become an important standard for this group in which we recommend applying it strategically and seizing opportunities for transparency. 
• Doing a double materiality assessment (DMA) also remains an important strategic tool for this group. It provides insight into key risks and opportunities and helps provide focus. 
• The core remains making progress on one's sustainability ambition, further developing policy or transition plans, implementing action plans, measuring impact, or developing objectives for resilience and a future-proof strategy. CSRD offers valuable tools for this, especially if they can be deployed more independently. 

Assurance developments and recommendations  

Assurance increases the quality and reliability of reporting. 

• Reporting with limited assurance may no longer be mandatory. It can still be done voluntarily. Stakeholders and chain partners, commercial partners, or covenants (e.g. banks, investors, customers, sector agreements) may request reporting on specific components or KPIs. There is the possibility of applying assurance on these components (e.g. the CO2 footprint or transition plan), so that stakeholders have reliable data for their decision-making.  
• It remains wise to coordinate with the auditor on the processes and reporting approach, especially if voluntary assurance is being considered.