CSRD after the Omnibus: Why Doing Nothing Is the Riskiest Strategy

When the sustainability Omnibus package was approved, and approximately 80% of companies fell out of CSRD scope, many expected organizations to scale back their sustainability reporting efforts. The opposite happened. Research from osapiens reveals a striking paradox: 90% of companies no longer required to report under CSRD plan to continue or expand their sustainability reporting — yet 84% of these same organizations expect reduced internal resources for sustainability activities. 

This resource gap reveals the critical challenge facing organizations today. The business case for sustainability data remains strong. Stakeholder expectations haven’t diminished. But internal justification becomes fragile when regulatory pressure eases. For organizations navigating this tension, the question isn’t whether to continue building capability. It’s whether to build strategically now, or to rebuild expensively later. 

Sustainability demands stay high, but resources are shrinking 

The Omnibus I changed reporting obligations, but it didn’t change what customers, investors, and financial institutions require. Large enterprises still need supplier sustainability data to complete their own value chain disclosures. Banks still incorporate ESG metrics into financing decisions. Procurement teams still evaluate sustainability criteria alongside traditional commercial factors. 

Yet organizations planning to continue sustainability reporting face a resource constraint. Teams dedicated to reporting shrink as compliance urgency fades. Budgets for reporting sustainability data tighten when regulatory deadlines extend. Systems run by dedicated resources become fragile when maintained by fewer people while managing competing priorities. 

The impact of these changes isn’t immediate. Data collection shifts from systematic to reactive. Audit trails weaken gradually. Response times to stakeholder requests lengthen over months. By the time regulatory requirements tighten or commercial pressure intensifies, organizations face a predictable challenge: rebuilding infrastructure they previously had, under compressed timelines, with incomplete historical data. 

The business costs of delaying sustainability reporting 

Delaying sustainability reporting capability creates measurable costs across market access, financing terms, and competitive positioning. These costs compound over time, creating gaps that become expensive to close.  

The pattern plays out across industries. Three scenarios illustrate how delay creates tangible business costs: 

Missed deals due to missing sustainability data 

A manufacturing company responded to a major automotive tender with strong technical capabilities and competitive pricing. The RFP included sustainability data requirements — carbon footprint, supply chain compliance, resource management metrics. The manufacturer had solid operational practices but no structured documentation of the required sustainability data. Eliminated at preliminary evaluation, the contract went to a competitor with established sustainability reporting systems. The differentiator wasn’t operational performance. It was data visibility. 

Higher financing costs due to missing sustainability data 

Two logistics companies with similar financial profiles refinanced fleet modernization with the same bank. One had established structured sustainability reporting. The other maintained good practices without formal documentation. The documented company qualified for sustainable finance terms — 75 basis points lower, tied to verified sustainability KPIs. The company without documentation received standard rates. Over five years, this financing differential represents significant additional cost that systematic reporting infrastructure would have avoided. 

Lost deals due to slow data response 

A food ingredient supplier established VSME reporting despite operating outside regulatory scope for mandatory sustainability reporting. When their retail customers accelerated sustainability data requirements during the post-Omnibus period, this supplier responded within weeks with comprehensive, verified information. Competitors needed months to assemble comparable documentation. Result: expanded volume allocations, multi-year supply agreements, and preferred supplier positioning that competitors struggled to challenge. 

The competitive advantage wasn’t sustainability performance — many competitors had comparable operational practices. The advantage was having systems that could generate verified sustainability data on demand. While others assembled data retrospectively, this organization had reporting infrastructure that produced stakeholder-ready outputs as part of normal operations. 

These scenarios reflect patterns described regularly across industries: capable organizations losing ground not because of poor sustainability performance, but because they lack the data infrastructure to demonstrate it when commercial opportunities require it. 

Reactive vs. proactive sustainability reporting 

Organizations face a fundamental choice about how to approach sustainability infrastructure during regulatory uncertainty. This choice shapes their positioning when requirements change. 

Dimension	Reactive Approach	Proactive Approach
Response Time	Months to assemble data when stakeholders request; customers wait or move to alternatives	Weeks to respond with comprehensive verified data; meet commercial timelines consistently
Data Quality	Estimated baselines; gaps in historical records; inconsistent methodologies; weak audit trails	Systematic collection; documented methodologies; continuous audit trails; assurance-ready
Market Position	Disadvantage in procurement; excluded from sustainability-focused opportunities; higher capital costs	Preferred supplier status; access to sustainable finance; competitive differentiation in tenders
Cost Structure	Emergency consultant engagements; retroactive data reconstruction; lost opportunity costs; technical debt	Systematic infrastructure investment; automation efficiency; operational insights; lower long-term costs

The difference between these approaches isn’t visible immediately. It becomes clear when regulatory requirements tighten or when customers accelerate data request timelines. Organizations that maintained capability are responding. The others are explaining delays and negotiating extensions. 

How to build efficient sustainability reporting without expanding scope 

Organizations don’t need full CSRD-level reporting to maintain strategic capability. They need infrastructure that keeps data flowing systematically, processes documented clearly, and teams prepared to respond when requirements change. This means focusing on efficiency rather than expanding scope. 

For mid-market organizations: VSME as strategic foundation 

An osapiens study found that 42% of organizations are using VSME (Voluntary Standard for SMEs) as their reporting framework. VSME provides structured reporting aligned with ESRS principles without requiring dedicated sustainability departments or full enterprise-level complexity. 

VSME offers practical advantages for resource-constrained organizations. Simplified templates reduce implementation time and cost. Framework alignment ensures credibility when responding to customer requests. Scalability allows expansion to full CSRD if requirements evolve — without rebuilding infrastructure from scratch. 

Organizations establishing VSME-level capability can respond credibly to commercial requirements, participate in procurement processes that evaluate sustainability criteria, and access financing products that reward transparent sustainability reporting. The framework provides the foundation that makes these opportunities accessible without creating unsustainable administrative burden. 

For enterprise organizations: maintaining multi-framework readiness 

Large enterprises managing global operations and diverse stakeholder requirements benefit from maintaining capability across multiple reporting frameworks. The osapiens study Beyond Compliance: Sustainability Reporting after the Omnibus shows that nearly half of surveyed organizations continue using ESRS alongside other standards like ISSB, GRI, and bilateral customer requirements. 

Multi-framework capability doesn’t require maintaining separate reporting processes. Organizations using consolidated platforms report once and adapt output to different stakeholder requirements. Data flows from operations, finance, and supply chain systems feed a unified data model. Framework-specific formatting adjusts without rebuilding underlying infrastructure. 

This approach reduces reporting cycle times while maintaining data quality. When investors request ISSB disclosure, customers require GRI reports, and regulators expect ESRS compliance, organizations respond from the same underlying data infrastructure rather than managing parallel reporting processes. 

Using sustainability data for operational and cost insights 

Reporting infrastructure generates value beyond stakeholder disclosure. Organizations using sustainability data systems systematically surface operational insights that drive business decisions independent of compliance requirements. 

Structured data collection reveals resource consumption patterns that identify cost reduction opportunities. Supply chain visibility highlights risk concentrations before they create disruptions. Energy and waste metrics support facility-level efficiency improvements. These operational benefits accrue regardless of regulatory requirements — they result from having systematic data infrastructure rather than fragmented spreadsheets. 

This operational intelligence creates the business case for maintaining capability during regulatory uncertainty. Organizations using reporting infrastructure to optimize operations, identify risks, and support decision-making develop internal stakeholders beyond the sustainability team. When finance teams use resource consumption data, operations teams track efficiency metrics, and procurement teams evaluate supplier risk, sustainability infrastructure becomes embedded in business operations rather than isolated in compliance functions. 

Regulatory uncertainty as a strategic advantage 

Regulatory timelines will evolve. Stakeholder expectations will intensify. Market standards will shift. What remains consistent is the advantage that prepared organizations hold when these shifts occur. 

Organizations that maintained reporting capability through previous regulatory changes emerged stronger when requirements tightened. Those that waited faced compressed implementation timelines, higher costs, and competitive disadvantages that took years to close. The pattern repeats: early movers capture advantages that late responders struggle to match. 

Omnibus created a decision point. Organizations can treat regulatory uncertainty as permission to pause, or they can use this period to build strategic reporting capability while competitors delay, turning temporary inaction into lasting advantage. 

The difference between these approaches becomes visible not during periods of regulatory relief, but when requirements tighten and commercial pressure intensifies. By then, organizations that continued building are responding within weeks. The others are rebuilding from scratch, under pressure, with incomplete data. 

Doing nothing is not neutral — it’s the riskiest strategy available. 

Scale sustainability reporting with the osapiens Reporting Cockpit 

The osapiens HUB Reporting Cockpit enables organizations to maintain reporting capability efficiently during regulatory uncertainty. Built for both mid-market organizations establishing initial VSME reporting and enterprises managing multi-framework requirements, the platform consolidates sustainability data without creating administrative burden. 

For mid-market organizations, Reporting Essentials provides VSME-aligned templates with streamlined workflows that don’t require dedicated sustainability teams. For large enterprises, the platform handles ESRS, ISSB, GRI, and bilateral customer requirements through unified data infrastructure with REST API integration, automated validation, and audit-ready documentation. 

Organizations gain response times that compress from months to weeks when stakeholders request data, systematic audit trails that support external assurance requirements, and framework-agnostic infrastructure that adapts when requirements change without requiring rebuilding. 

The platform doesn’t eliminate the work of sustainability reporting. It eliminates the inefficiency that makes reporting feel unsustainable when resources tighten and priorities compete. 

Pre-save our guide: “From Data to Decisions: Unlock Business Impact Through Sustainability Reporting” — Learn how to build reusable sustainability data infrastructure that costs less now than rebuilding when stakeholder pressure intensifies. 

Available May 2026 

Related Resources: 

• Why Customers Expect Sustainability Reporting Before Regulations Apply  
• VSME Implementation Guide: Simplified Reporting for Resource-Constrained Organizations 
• The Evolving CFO: A CFO’s Guide to Managing Finance and Sustainability Reporting