Omnibus I: EU Parliament votes in favor of “stop-the-clock” regulation

Shortly before this, the Commission had instructed EFRAG to submit a significantly revised version of the ESRS by October 31, 2025. In doing so, the mandate to EFRAG was specified with concrete fields of action: 

• Significant reduction in the number of mandatory ESRS data points 
• Clear definitions of unclear terms in the standards 
• Clearer instructions on the application of the materiality principle (avoidance of over-reporting)
• Improved interoperability with other EU legislation and global standards

How can the time gained be used? What should companies focus on now?

The time gained by the postponed reporting should now be used to define and implement corporate sustainability performance and thus to build resilient business models.

Identify ESG issues, define sustainability performance

In this way, companies gain time to continue analyzing the ESG issues that are material to them and to translate them into concrete sustainability measures in line with their strategy and business model. Topics for concrete measures often include energy and emissions management, the operationalization of net zero plans, the implementation of climate risk and climate resilience analyses and the derivation of targeted remedies or the implementation of concepts for occupational safety and occupational health management.

• Conduct a double materiality analysis 
• Define and implement sustainability performance

Knowing the drivers of sustainability and identifying stakeholder interests

Although the EU has initially postponed reporting on sustainability, it has left no doubt that the sustainable transformation initiated by the EU Green Deal and further emphasized by the Clean Industrial Deal will continue to be implemented. Net zero targets, supply chain due diligence and the EU Deforestation Regulation require companies to implement specific measures. In addition to regulation, most of the drivers for sustainability arise from the market itself. The expectations of customers and business partners regarding transformation not only have an impact on the various business areas, but also on market positioning, reputation, access and costs of financing. Last but not least, the economic success of entire industries depends on the availability, price stability and efficient use of scarce resources such as raw materials and energy. In addition, the attractiveness of employers for qualified personnel remains a driver for the social aspects of sustainability. Therefore, the following is important:

• Knowing and actively monitoring company-relevant drivers for sustainability 
• Knowing and integrating stakeholder groups with their interests and influence

Identify, collect and report controlling-relevant ESG data in an integrated and automated manner

Management-relevant data relevant should be collected for each material ESG topic and made available internally and externally for reporting and controlling with the help of KPIs. The stronger the integration of data collection processes and the connection to existing data warehouse structures, the more naturally the data will be used for controlling purposes. Due to the reporting and controlling relevance of the data and information in particular, regular monitoring of the processes and the implementation of controls and checks are useful in order to strengthen confidence in the information. Targeted automation of the data collection and reporting processes can significantly increase the timeliness and therefore the relevance of information for controlling purposes. Last but not least, material ESG issues that are associated with risks must be consistently included in risk management and actively managed. These include, in particular, risks that could jeopardize the company’s continued existence, such as climate and environmental risks, a lack of know-how and the inability to insure or finance corporate activities.

• Consistently linking material ESG topics and relevant KPIs and incorporating them into ongoing controlling and risk management 
• Setting up integrated data collection processes and structures and implementing process controls

Knowledge building, qualification, DryRun for reporting and external review

Companies can use the time gained in the course of the “stop-the-clock” regulation for further training of key personnel or the entire workforce. Benchmarking within your own industry and evaluating best practices can also be helpful in developing your own reporting in an efficient and results-oriented manner. A look at the selection of topics, the structure and scope of reporting and, of course, the comparison of KPIs can provide valuable insights. A “test” report can be used to gain experience on how sustainability reporting can be ideally integrated into the annual report. Last but not least, a preparation and audit process that is harmonized with the financial reporting is also relevant for the smoothest possible process. On the basis of an initial audit, efficiency gains and an equalization of audit procedures by an external auditor are also possible in subsequent years. 

• Benchmark and, if necessary, adjust topic selection and report format 
• Create and check reporting schedules and plan test runs