Accountancy Europe’s initial comments on EC first omnibus package on sustainability

Accountancy Europe takes note of the European Commission’s first omnibus package to simplify sustainability rules, which covers several legislative sustainability initiatives, including the Corporate Sustainability Reporting Directive (CSRD). 

We remain committed to the EU Green Deal and the path to a net zero economy. Reassessing requirements is an important aspect of good lawmaking, ensuring that only what is necessary remains to achieve underlying policy objectives. We fully support efforts to cut administrative and reporting burdens for EU companies—simplifying without backtracking on policy goals. 

The CSRD has been or is in the process of being implemented by companies. For those Member States that have already transposed the CSRD, absorbing such rapid changes could be challenging.   It is important to maintain legislative consistency, avoid uncertainties and additional burdens on companies already working to comply which can undermine trust in EU legislation. 

Accountancy Europe and its members stand ready to contribute with expertise. Our CEO Eelco van der Enden commented: 

“Any improvements should ideally be made on the basis of learning from experience and ensuring certainty for companies. For instance, we have consistently flagged issues with the CSRD, including on the granularity of the reporting standards (ESRS). We will play our part to help ensure that the legislative calibrations deliver meaningful simplification, do not undermine key objectives, and achieve a balance between reducing burdens and minimising disruptions for ongoing compliance efforts.” 

Together with our experts, we will analyse the proposals in more detail. We, however, share below our immediate reactions to specific amendments. 

Scope 

We note the proposed amendments to defer the reporting requirements for companies that fall under ‘wave 2’ and ‘wave 3’ by two years. 

Regretfully, this will result in less available information regarding companies’ sustainability performance and financial risks stemming from sustainability developments. However, we understand that this approach will allow policymakers, supervisors, and preparers additional time to gain insights from practical implementation and enhance their readiness for sustainability reporting. Postponing the reporting obligations for these entities will also delay the assurance process for their sustainability reports, offering valuable lessons for both preparers and assurance providers. 

‘Value chain cap’ 

We welcome the reinforced provisions to protect SMEs from undue data requests. The use of the voluntary SME (VSME) standard as a legally binding value chain cap, and the more explicit wording reinforcing the cap’s functioning, are positive steps that we hope will help reduce burdens on and streamline expectations from SMEs. 

Assurance 

Independent external assurance enhances information credibility and supports investors and other users in making decisions related to sustainability matters. 

We have always advocated for consistent and high-quality assurance engagements across Europe. We, therefore, welcome the provisions on assurance, suggesting issuing targeted assurance guidelines by 2026. Given today’s environment, we recognise the need to re-evaluate the potential transition to reasonable assurance.