EU Omnibus: What companies should do now

CSRD, ESG & the Omnibus Regulation: The status quo

With its draft Omnibus Regulation of February 26, 2025, the EU Commission proposes to adapt the scope and timetable of the Corporate Sustainability Reporting Directive (CSRD): Not all companies would therefore have to report immediately in accordance with the new standards. Under the proposal, many companies that were originally affected from 2026 would have until 2028 - or would be exempt from the obligation altogether.

What sounds like an administrative relief at first glance raises new questions in practice:

• What does this mean in concrete terms for our ESG strategy?
• Is it still worth getting started - or does it make sense to wait?

But be careful: if you put it off now, you are wasting opportunities - and run the risk of being indirectly affected and realizing it too late. Because: ESG requirements do not disappear. They are shifting.

ESG pays off - even without obligation

Regardless of the regulatory framework, environmental, social and governance (ESG) issues are becoming increasingly important in almost all business relationships. Today, companies are under scrutiny - not only by supervisory authorities, but also by a large number of stakeholders who specifically ask about ESG criteria:

• Customers: What standards apply in production and the supply chain? Is there transparency regarding origin and environmental impact?
• Applicants: What does the company stand for socially? How seriously is climate protection, diversity or equality taken?
• Investors and capital providers: What ESG risks exist? Is there measurable progress in CO₂ reduction or governance?
• Banks and funding providers: How resilient is the business model in the face of regulatory and climate-related changes?

These requirements also affect companies that are not directly subject to the CSRD. The reason: the trickle-down effect.

What is the trickle-down effect?

The trickle-down effect describes the passing on of regulatory requirements along the supply chain. Large companies that are required to report in accordance with CSRD are also obliged to collect ESG data from their partners and suppliers.

In concrete terms, this means

• Producers are asked about CO₂ emissions, fair wages and energy consumption.
• Service providers must provide information on diversity, working conditions and governance.
• Retailers require proof of social and ecological standards in the supply chain.

Those who do not have this information prepared as soon as the request comes in may no longer be considered for tenders or supplier audits. ESG thus becomes a strategic competitive factor - regardless of any formal reporting obligation.

CSRD postponed is not canceled

The Omnibus Regulation postpones deadlines, not the direction. Companies that start with ESG now will benefit on several levels:

• Early structures save resources: if you take a systematic approach now, you don't have to react under time pressure later.
• ESG measures also work without a report: CO₂ reduction, supplier screenings or social standards strengthen the operating business, reduce risks and lead to cost savings.
• Credible communication creates trust: Companies with a clear ESG strategy score points in tenders, financing and employer branding.

What steps companies should take now

Even if the Omnibus Regulation gives many companies more time for mandatory CSRD reporting or eliminates the obligation altogether, now is the right time to strategically position yourself. After all, those who create ESG structures today will benefit tomorrow from clear processes, lower risks and a lasting boost of confidence from all stakeholders. The following four steps offer a practical roadmap.

1. implement simplified double materiality

The dual materiality analysis is at the heart of every sustainable corporate strategy - and a central component of the CSRD. It assesses which ESG issues are financially material for the company (outside-in perspective) and what impact the company has on the environment and society (inside-out perspective).

A simplified form of this analysis is also useful for companies that are not (yet) subject to CSRD: it helps to sharpen the ESG focus, recognize risks, identify opportunities and define prioritized fields of action. This creates a reliable basis for the ESG strategy.

According to the European Financial Reporting Advisory Group(EFRAG), the materiality analysis can be adapted depending on company size, sector and complexity.

Advantages:

• Clarity on relevant ESG issues for your own business model
• Focus on measures that are actually effective
• Establishing a sound ESG strategy at an early stage
• Basis for the fulfillment of future reporting requirements (e.g. CSRD or VSME)

2. set up automated, standardized ESG data collection

The analysis is followed by the structured collection of ESG data - focused on the topics that are actually material. It is important to collect the right data rather than as much data as possible. It is important to be guided by the applicable standard:

• Companies that fall under the VSME standard can fall back on a simplified reporting structure.
• Companies with CSRD-related issues should refer to the ESRS (European Sustainability Reporting Standards).

A central element is the carbon footprint: it forms the basis for climate strategies, decarbonization measures and investment decisions - and is an increasingly popular KPI for banks, business partners and public clients.

Advantages:

• Reliable database for ESG planning and communication
• Reduction of manual effort through automation
• Standard conformity and connectivity to report formats
  

3. derive ESG measures with impact

Once the key issues have been identified and relevant data collected, specific ESG measures can be developed. It is crucial that these are strategically aligned and have a sustainable impact - both operationally and communicatively.

Based on the CO₂ balance, for example:

• formulate a realistic reduction path to 2030 or 2050,
• Prioritize decarbonization measures (e.g. energy efficiency, sustainable mobility, purchasing criteria),
• and set measurable targets for social and governance-related development.

Advantages:

• ESG as part of corporate development, not as an isolated project
• Synergies between sustainability and efficiency (e.g. energy savings)
• Preparation for regulatory requirements such as EU taxonomy or SBTi
  

4. making impact visible - for stakeholders and the market

Sustainability only becomes a competitive advantage if it is visible. Banks, investors and business partners can only evaluate ESG performance if it is communicated in a comprehensible manner - be it in ESG reports such as VSME or CSRD, on the website, social media or other platforms. The desired effect is only achieved through this visibility: trust, access to capital, better market position.

Advantages:

• Greater visibility and reputation in the market 
• Better positioning for tenders and financing 
• Strengthening the employer brand and employee loyalty 

Implement ESG pragmatically with Planted

Planted helps companies of all sizes to implement ESG requirements in a structured and future-proof manner. Our platform combines sound advice with intelligent software that supports companies at every step of their ESG strategy.

• Strategic entry: We help you to identify relevant topics for your company as part of a simplified double materiality analysis. In addition, you will receive a set of impacts, risks and opportunities (IROs) proposed by AI - tailored to your company's specific sector. You can build your entire ESG strategy on this basis.
  
  
• Automated data acquisition: ESG data is specifically integrated, checked and analyzed for VSME or ESRS - with interfaces to existing systems. The focus is solely on the relevant data points.
  
  
• Measures with impact: Based on the analysis, Planted AI determines specific ESG measures - prioritized according to impact, feasibility and strategic relevance, but also with a view to the return on investment (ROI) desired by your company. You can implement these across teams with your employees and transform the company from the inside out.
  
  
• Communication with substance: progress is documented in a comprehensible manner as a VSME or CSRD report. Your personal impact page also shows your company's overall commitment and can be communicated to stakeholders.

Whether a voluntary start or preparation for mandatory reporting: Planted makes ESG plannable, efficient and connectable for companies. Get started now and position your company as a competitive leader. Book a free consultation now.