How to maximize your impact with sustainability reporting in 2026

For many mid-sized and large companies, especially those operating in multiple markets or serving complex supply chains, the Omnibus does not substantially change what needs to happen in 2025. The regulatory news cycle is loud, but the underlying business reality and strategic relevance are as prominent as ever.

The regulatory headlines are louder than the underlying facts

The Omnibus introduces changes to scope, timing, and some disclosure details. These changes matter, but they do not eliminate the broader forces that continue to shape sustainability reporting across global markets.

Key drivers remain in place:

• Investor expectations for climate risk and transition planning
• Lender and insurer requirements that influence access to capital
• Supply chain disclosure pressures, including scope 3 expectations  and working conditions
• Customer and procurement standards
• Global alignment to ISSB, TCFD, and GRI
• Workforce expectations and credibility in talent markets

These forces do not depend on whether a company falls inside a revised CSRD threshold. They exist because organizations need reliable information to make decisions, manage risk, and demonstrate performance to stakeholders who rely on comparable data.

This means most companies will continue for strategic reasons, not because they are legally compelled to do so.

Organizations have already invested heavily in their reporting capabilities

Over the past several years, a significant number of companies have established sustainability reporting processes that go beyond basic compliance. These investments include:

• Structured data pipelines
• Establishing linked corporate and sustainability strategies
• Internal controls and validation procedures
• Cross-functional roles and responsibilities
• Supplier engagement processes
• Emissions baselines and forecasting models
• Regular internal reporting cycles

These capabilities have operational value that is independent of regulatory scoping. They improve visibility, support planning, and inform financial and operational decisions. As a result, companies rarely dismantle these systems once they are in place.

The idea that businesses will revert to pre-framework behaviors assumes that compliance was the primary motivation. In reality, many organizations relied on the frameworks as a way to structure work and follow up on strategic targets.

Frameworks provided structure, not only obligations

Frameworks such as ESRS, TCFD, ISSB, and GRI help companies move from scattered initiatives to more structured approaches. They offered:

• Clear definitions and expectations
• A shared internal language
• Improved comparability
• More reliable planning inputs
• A consistent view of what good disclosure looks like

Even if certain legal requirements shift, the value of the underlying structure remains. Visibility into emissions, human rights risks, and supply chain impacts gives companies a clearer picture of their performance and enables more informed decision-making.

There is no practical reason to give up that clarity once it has been established.

Value creation depends on capability, not on box checking

There is a common misconception that meeting reporting requirements directly produces value. The truth is more practical. The value comes from having the capabilities needed to act on insights. Reporting provides the foundation for better decisions, and that is where companies begin to see results.

Examples include:

• Identifying cost-saving opportunities in energy and resource use
• Lowering insurance exposure through improved risk management
• Qualifying for tenders that require sustainability data
• Building stronger relationships with lenders and investors
• Reducing supply chain disruptions
• Identifying new markets or opportunities based on performance insights

These outcomes are tied to data, structure, and consistency and should not depend on regulatory shifts and uncertainty.

Not all companies are in the same place

Some organizations may temporarily reduce the pace of their reporting work, particularly if they have not yet established internal structures or systems. This variation is expected.

However, the companies that have already built cross-functional processes, improved their data quality, or aligned with global frameworks are unlikely to reverse course. Their decision-making relies on visibility, and visibility requires ongoing reporting.

This distinction helps make clear that continued reporting activity is a rational business choice, not a response to any particular software provider or vendor.

Practical steps for sustainability reporting in 2025

Below are concrete actions sustainability teams can take to prepare for the year ahead. They apply regardless of whether the Omnibus affects your formal obligations.

1. Strengthen your data foundation

Reliable data is essential for internal decision-making and for external credibility.

Focus on:

• Consolidating data sources
• Improving data quality and audit trails
• Ensuring consistency across reporting periods
• Documenting assumptions and methodologies

For companies that want a clear starting point, Position Green’s benchmarking solution can help establish where your current performance sits relative to peers and competitors. This can clarify whether your internal targets are realistic, too conservative, or not aligned with industry practices.

2. Refine materiality and scope

Materiality should guide your reporting priorities and strategic decisions.

Actions include:

• Updating your double materiality assessment or ISSB-aligned materiality assessment
• Reconfirming which topics are financially or operationally significant
• Reprioritizing resources and strategic focus based on outcome

This ensures your reporting focuses on the issues that matter most to your organization rather than reacting to external narratives.

3. Maintain alignment with leading frameworks

Even if certain ESRS requirements shift, the framework remains a strong reference point. Maintaining alignment with ESRS, ISSB, and TCFD helps keep reporting structured, comparable, and ready for assurance.

Practical steps:

• Map your disclosures to global frameworks
• Update your internal controls and documentation
• Track areas where additional granularity is needed

4. Build governance and internal coordination

Stronger governance reduces risk and increases efficiency.

Consider:

• Clarifying roles and ownership across sustainability, finance, compliance, and operations
• Establishing regular cross-functional check-ins
• Creating a clear escalation process for data issues
• Strengthening board oversight and documentation

5. Prepare early for assurance

Assurance expectations are rising globally.

Good preparation includes:

• Documenting methodologies
• Identifying high-risk data areas and gaps
• Conducting internal or external pre-assurance
• Ensuring consistency across business units

6. Use benchmarking to set meaningful targets

Benchmarking provides a realistic view of where your organization stands relative to peers. It allows you to:

• Identify areas where you outperform or lag
• Set targets that are grounded in industry norms, stakeholder expectations and ambition level
• Understand which metrics matter most in your sector
• Communicate performance to stakeholders more effectively

Position Green’s ESG Benchmarking solution uses validated, real-reported data from thousands of companies, without proxies. This allows you to calibrate your goals based on actual market performance rather than assumptions. It can also help you identify the most impactful opportunity areas before setting or updating your 2025 targets.

Maintain your momentum with us

The Omnibus may shift parts of the regulatory landscape, but it does not change the underlying drivers that shape sustainability reporting. Organizations that have invested in data quality, governance, and internal capability are unlikely to reverse course. Their reporting supports strategic decision-making, financial resilience, and operational clarity.

For sustainability professionals, 2025 is a year to focus on data, alignment, governance, and realistic target setting. Benchmarking can support these efforts by offering a clear view of where your organization stands and what goals are achievable in your market.

Sustainability reporting is not being undone. It is maturing, and companies that keep building on their capabilities will be better equipped for the years ahead.