[CSRD] Omnibus Directive: no pause for sustainability, but an opportunity to get ahead
What this article contains: (I) A clear overview of the ongoing changes; (II) A strategic decoding of the European context; (III) Our pragmatic recommendations to continue moving forward effectively.
As you know, the Omnibus bill is on everyone's lips. Easing of CSRD requirements, relaxation of timelines... for some, this might look like a pause.
At NSW CONSEIL, we think on the contrary it is time to step back. Behind these adjustments,the underlying trend remains unchanged: sustainability is at the heart of the European strategy and is becoming a key factor for business competitiveness.
I. What the Omnibus Really Contains
Two proposals currently being discussed:
➡️ Exclude from CSRD companies with fewer than 1,000 employees;
➡️ Postpone the first CSRD reporting from 2026 to 2028 for certain companies
At this stage, these elements are proposals, not yet adopted. The adoption procedure could take 6 months to 1 year, and their implementation until the end of 2028. Nothing justifies slowing down the structuring of your sustainability strategy.
To help you see more clearly, find our indispensable cheat sheets: (i) The changes proposed by the Omnibus on the CSRD, (ii) The upcoming legislative calendar, with the next key steps.
II. Take a step back: What the Omnibus really reveals about the European trajectory
At NSW CONSEIL, we think what matters is not what the Omnibus proposes, but what it reveals about the European trajectory.
Competitiveness and sustainability are now treated equally
The 2024-2029 mandate of the European Commission marks a new stage: after having established sustainability as a strategic priority within the Green Deal framework, the European Union is now seeking to combine economic competitiveness and sustainable transition (1). The objective: make sustainability a lever for prosperity for European companies, and not an additional constraint.
The role of regulation is declining in favor of financial markets
The framework is in place (CSRD, Taxonomy, SFDR). Now, the EU is betting on flexible regulation and letting markets play their role. Financial actors (investors, banks, insurers) now demand transparency by asking for reliable data to guide their decisions.
Lessons to be learned
➡️ The transition towards a sustainable economy is underway, with or without the Omnibus.
➡️ Financial markets now drive the ESG transparency requirement, determining companies' access to financing and their valuation.
➡️ Sustainability is no longer just a regulatory compliance topic: it is becoming a real competitiveness lever for companies able to structure and showcase their sustainable performance.
In summary, anticipating and structuring your sustainability information is now a strategic lever for accessing financing, improving competitiveness, and meeting market expectations.
III. Our Standpoints and Recommendations at NSW CONSEIL
Our conviction is simple: do not depend on the legislative calendar to act.
We recommend to:
Initiate and/or finalize the double materiality analysis, to identify your strategic priorities and meet stakeholders' expectations, both internal and external;
Produce a “lightweight” but structured and robust reporting, designed not only to demonstrate your commitments, but above all to connect your non-financial and financial data, in order to manage your sustainable performance as a strategic lever;
Structure and secure your sustainability data, to gain agility and reactivity regarding regulatory changes and market requirements.
This approach is what will allow you to turn the CSRD into a competitiveness tool, rather than a regulatory constraint.
👉 Contact us to discuss!