In February 2025, the European Commission released proposals for simplifications concerning, among other things, CSRD reporting, known as the Omnibus proposals. The background to the changes is that they want to simplify the administrative processes to reduce costs and strengthen the EU's competitiveness. The requirements for the EU taxonomy, CSDDD and CBAM are also proposed to be changed.

In April, the European Parliament voted through the 'Stop the clock' proposal, which postpones several of the implementations of CSRD, CSDDD and EU taxonomy.

In order to prepare for the upcoming requirements, it is crucial that your company identifies which category - wave 1, 2 or 3 - you belong to among the reporting entities. This will help you understand how the new rules will affect your sustainability reporting timeline.

Wave 1

Companies classified in wave 1, i.e. larger companies or public interest groups with more than 500 employees, are not subject to any change in the timetable. These companies will continue to submit their reports according to the previous schedule.

Waves 2 and 3

For Wave 2 and 3 companies, the introduction of the reporting requirements has been postponed by two years. This means that:

• Larger companies will have to start complying with CSRD from the financial year 2027.
• Listed SMEs and some smaller financial institutions will start reporting from the financial year 2028.

Pause in application ("Stop the clock")
In addition, the 'stop the clock' decision means that the introduction of sustainability due diligence rules is also postponed by one year. This applies in particular to the largest companies with more than 5,000 employees and a net turnover of more than €1.5 billion - for these, the requirement will not apply until July 26, 2028.

Next steps

The Council of the European Union has now voted on and approved the deferred application. Each country now needs to implement the changes in national law.

It is only the timing aspect that has been addressed so far. Changes to the scope and content of the requirements have not been discussed and there is no date for a vote on this yet.

CSRD reporting is important from several perspectives. First, it creates greater transparency about companies' sustainability work through specific reporting requirements. Second, the regulations make it easier for investors to make sustainable choices. Third, CSRD is expected to drive more sustainable development throughout the business community. Companies that adapt early to CSRD can strengthen their competitiveness and attract informed consumers and customers.

To comply with CSRD , companies are required to:

1. Develop a sustainability strategy: A clear strategy that describes the company's sustainability goals and how they will be achieved.
2. Collect data: Companies need to collect data on their operations to report on their sustainability impact.
3. Report according to standards: Reporting must comply with the European Sustainability Reporting Standards (ESRS).
4. Continuously improve: Sustainability is a continuous process and companies need to regularly evaluate and improve their efforts.

Double materiality analysis is a mandatory part of CSRD, and aims to analyze how a company affects the world and the environment through its activities (outward perspective), as well as how the world affects the company (inward perspective) in the event of, for example, weather extremes.

The outward perspective looks at the environmental impact of companies and the inward perspective looks specifically at the financial risks of companies if, for example, an unexpected weather event occurs.

The double materiality analysis also aims to identify and prioritize the most relevant sustainability issues, through a so-called materiality assessment.

VSME covers the same sustainability categories as CSRD, such as climate impact, water use, biodiversity, labor and governance, but contains several important differences:

1. Mandatory vs. voluntary reporting

• ESRS: Mandatory for large companies under CSRD.
• VSME: voluntary and targeted at SMEs outside the scope of the CSRD.

2. Reporting principle

• ESRS: Requires a double materiality assessment (DMA), where companies must assess both how sustainability issues affect the company and how the company affects the environment and society.
• VSME: Follows an "if applicable" principle, which means that companies only report on those ESG topics that are relevant to their business.

3. Reporting structure and scope

• ESRS: Comprehensive requirements with detailed quantitative information and action plans.
• VSME: Modular structure with two levels: a basic module with 11 items of information and a comprehensive module with 9 additional items of information. The reporting allows for simpler, narrative-based answers.

4. Publication

• ESRS: Requires disclosure of sustainability information in accordance with CSRD.
• VSME: No disclosure requirement. SMEs can choose to share their report with specific stakeholders, such as investors.

5. Support and guidance

• ESRS: Detailed guidance and requirements, but can be complex for SMEs to implement without external resources.
• VSME: Developed with the limited resources of SMEs in mind, with simplified requirements and supporting material to facilitate implementation.

The VSME standard does not require a formal Double Materiality Assessment (DMA). Instead, VSME applies the principle of "where applicable", which means that you only report on the ESG aspects that are relevant to your business.

However, even if DMA is not a requirement, a basic materiality assessment can still be very valuable. By examining how your company impacts people and the environment, and how sustainability issues affect your business, you will get a clearer picture of where you should focus your resources. It can make your reporting more accurate, but also:

• Laying the foundation for future compliance with CSRD and ESRS
• Strengthen the trust of investors, customers and other stakeholders
• Give structure to your internal sustainability work and risk management

And most importantly, a materiality assessment does not have to be complicated. A simple, internal process can go a long way as long as it is transparent and documented.