Sustainability Reporting After the Omnibus: When Compliance is no Longer the Reason to Report

The EU’s Omnibus I package has altered the sustainability reporting landscape in Europe. For some organizations, reporting obligations have been eased. Thresholds have been adjusted and timelines recalibrated, removing parts of the reporting population from immediate scope.

What this change has not resolved is not whether sustainability reporting will continue – most organizations indicate that it will – but how reporting can be sustained and justified when compliance alone is no longer sufficient.

This question sits at the center of the new osapiens report Beyond Compliance: Sustainability Reporting After the Omnibus. Based on a survey of over 400 senior decision-makers across the EU and the UK, the report examines how organizations are responding to the Omnibus decision and what conditions determine whether reporting remains durable beyond formal obligation.

Sustainability risks remain financially material and require structured disclosure

The Omnibus I package was introduced to reduce regulatory complexity and balance reporting requirements across sustainability regulations. However, the findings from our latest survey indicate that how sustainability information is used to evaluate risk by markets, partners, and decision-makers has not changed.

Sustainability risks continue to be considered financially material, and the expectation for structured, credible disclosure persists across capital markets, value chains, and business relationships. Even where formal reporting obligations have changed, the demand for reliable sustainability data remains strong.

As Andreas Rasche, Professor and Associate Dean at Copenhagen Business School, explains:

“The Omnibus has changed how sustainability reporting obligations apply, but it has not necessarily removed the underlying rationale for reporting. Stakeholder expectations for sustainability reporting still exist – from business partners, investors, banks, and from society more broadly.”

For companies, this creates a more confronting decision environment. Sustainability reporting can no longer be justified by regulatory obligation alone; its role and value must be clearly anchored within competing business priorities.

>> For a detailed breakdown of what Omnibus I changed, and what it didn’t, see our overview on sustainability reporting after the Omnibus here.

Companies choose continuity in sustainability reporting post-Omnibus

Despite the reduction in regulatory pressure, the survey results clearly show a preference for continuity in sustainability reporting. This directly contradicts the expectation of a post-Omnibus pullback in reporting activity.

According to the osapiens survey:

• 90% of organizations excluded from formal scope of CSRD plan to maintain or expand sustainability reporting
• 86% are confident they can continue reporting aligned with CSRD-level expectations
• Nearly 90% expect increased investment in reporting tools and automation in the next 12 months
• 90% already integrate sustainability reporting with financial reporting, partially or fully

These results suggest that sustainability reporting has moved beyond a narrow compliance function. For many organizations, reporting is no longer treated as a standalone exercise, but as part of broader planning, governance, and management processes.

As Rasche observes:

“The results show a clear preference for reporting continuity, even as policy shifts have caused uncertainty. This reflects the fact that many organizations have already embedded sustainability reporting into planning, governance, and internal decision-making.”

Continuity of reporting intent and activity, however, does not imply that reporting capabilities are protected from future resourcing, prioritization, or governance pressures – a gap that becomes critical over time.

High sustainability reporting intent meets declining resource allocation

One of the report’s most critical findings is the growing gap between intention and resourcing.

While most organizations plan to continue reporting, 84% expect reduced regulatory scrutiny to result in fewer resources being allocated to sustainability reporting over time. Budget constraints, fragmented data landscapes, and unclear ownership already pose challenges, and these risks increase when reporting is no longer externally enforced. This creates what the report describes as a “sustainability paradox”: reporting remains valuable, but increasingly fragile.

Rasche is explicit about the implications. If firms can no longer rely on compliance alone to justify sustainability reporting, “they must really consider the purpose of voluntary action and decide what role sustainability reporting plays in how they run the business”.

In other words, without a defined internal business case, sustainability reporting is likely to be deprioritized and stripped of dedicated resources over time – even if its importance is widely acknowledged.

Sustainability reporting: From regulatory obligation to decision infrastructure

One reason many organizations hesitate to roll back reporting is that sustainability data is already used far beyond formal disclosures. The survey shows it plays a key role in:

• operational and resource planning
• supply chain risk assessment
• financial planning and investment decisions
• innovation and process design

Nearly half of respondents identify improved visibility into operational, climate, and supply-chain risks as the greatest benefit of sustainability reporting.

Once sustainability data becomes embedded in high-impact decisions, removing it introduces blind spots into planning, risk assessment, and investment decisions. At that point, sustainability reporting functions as decision infrastructure, and scaling it back affects decision quality with tangible operational and financial consequences.

Voluntary reporting frameworks fill the gap

Post-Omnibus, organizations are not stepping away from structured sustainability reporting. Survey results show continued alignment with established reporting frameworks, even where formal CSRD obligations no longer apply.

Among respondents:

• 49% reference the European Sustainability Reporting Standards (ESRS)
• 42% align with the VSME framework
• 35% respond to bilateral disclosure requirements set by investors, banks, or key customers

These figures demonstrate that organizations continue to rely on structured reporting frameworks rather than ad hoc disclosure. For organizations not yet subject to the CSRD, or lacking the resources to implement full CSRD-aligned reporting, the VSME provides a scalable entry point for structured sustainability reporting (explained in detail here).

Key decisions shaping sustainability reporting

The Omnibus has shifted responsibility inward. Organizations now have to decide:

• what sustainability reporting enables internally
• where it supports risk management, valuation, or commercial access
• and how much reporting capability they are willing to protect without regulatory pressure

Explore the Full Report and Resources

Access the full report and webinar recording

The complete report Beyond Compliance: Sustainability Reporting After the Omnibus includes:

• detailed survey findings from 403 decision-makers
• a framework for building a durable business case for sustainability reporting
• six actionable steps to build your sustainability reporting roadmap

The findings have also been discussed in a webinar featuring Andreas Rasche and osapiens leadership, exploring what the Omnibus means in practice for the future of sustainability reporting.

>> Streamline your sustainability reporting with osapiens: discover how the osapiens HUB Reporting Cockpit consolidates sustainability KPIs across multiple frameworks into a single, audit-ready platform.