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ESG reporting readiness checklist for CFOs and sustainability leads

The EU Omnibus proposal aims to streamline and unify existing ESG regulations. While it signals a shift toward simplification, it does not eliminate expectations on transparency and reporting of sustainability data. Instead, it places more pressure on companies to ensure their reporting strategy and systems can flexibly serve multiple overlapping frameworks (ESRS, VSME, IFRS S2, TPT, etc.) and stakeholder needs.

The good news? Many of the foundational components that regulators and financial institutions expect—corporate governance, scenario analysis, risk assessments, carbon accounting—are shared across frameworks. If your organisation gets these right, you’re covering your bases and building a future-ready, efficient reporting system that drives business value.

Core readiness actions that apply across all frameworks

These are the foundational building blocks of any robust sustainability reporting strategy. They are fully or partially recognised across ESRS, IFRS S2, GRI, GFANZ, and other global standards.

Governance

☐ Board-level oversight is documented and active in sustainability matters.
☐ Executive incentives are aligned with ESG and climate performance metrics.
☐ ESG risk and opportunity considerations are embedded in company strategy.

Why it matters: Governance and Business Ethics are required disclosures across virtually all major frameworks. Transparency and strength here increases credibility and regulatory confidence.

Scenario analysis

☐ A scenario analysis model exists for decarbonisation pathways (e.g. 1.5°C alignment).
☐ Scenario results inform strategy development, risk planning, budgeting, and target setting.
☐ Your systems can model financial implications of sustainability risks.

Why it matters: Scenario analysis is one of the clearest value links between sustainability and (long term) financial planning—yet it’s underdeveloped in many organisations.

Risk and opportunities

☐ You’ve identified key ESG risks—including regulatory non-compliance, environmental impact and dependencies, social violations, and supply chain vulnerabilities
☐ You’ve mapped ESG opportunities for value creation, such as energy efficiency or green product innovation
☐ There is a documented risk response and mitigation strategy

Pro tip: This isn’t just about managing downside. Frameworks like IFRS S2 and ESRS now expect companies to quantify both financial risks and opportunities.

Strategy integration

☐ ESG risks and opportunities are linked directly to business strategy
☐ There is a decarbonisation 1.5°C-aligned transition plan integrated into strategic planning
☐ Feedback loops (e.g. stakeholder input, board reviews) inform and help continuously improve  your ESG decisions

Why it matters: Frameworks increasingly require evidence that sustainability is not siloed—it must connect to core strategy.

Financial planning

☐ Budget is allocated to key sustainability initiatives, ESG data and management systems
☐ Financial models include assumptions related to climate change, carbon pricing, transition costs, and opportunity scenarios
☐ Your finance team is trained in sustainability and empowered to engage with sustainability data

Real impact: Companies that embed sustainability into capital planning see greater clarity on ROI—and avoid underestimating future risks.

Target setting

☐ Emission reduction targets are in place—ideally both absolute and intensity-based
☐ Targets are validated (e.g. via SBTi) and mapped to ESRS or VSME expectations
☐ Internal reviews are scheduled to track progress and recalibrate where needed

Note: Net-zero targets and interim goals are not optional—they’re increasingly tied to financing conditions and risk disclosures.

Scope 1, 2, and 3 carbon accounting

☐ All three scopes of emissions are tracked with appropriate methodologies
☐ Scope 3 data is collected across the value chain
☐ Emissions are independently verified or verifiable

Why it matters: Carbon transparency is a common requirement across ESRS, IFRS S2, and GFANZ. It’s also a prerequisite for any meaningful decarbonisation pathway.

Value chain engagement

☐ ESG expectations are embedded into supplier contracts and assessments
☐ You have processes to collect data from suppliers, subsidiaries, and service providers
☐ Value chain data flows into your ESG reporting system—not just annual updates

Strategic edge: Companies with streamlined supplier engagement are not only more resilient—they’re more attractive to customers and investors.

Framework-specific add-ons

Here’s what you may need in addition depending on your reporting obligations:

If reporting under ESRS (European Sustainability Reporting Standards):

☐ Conduct a double materiality assessment (DMA) to define reporting scope
☐ Align your disclosures with EFRAG’s sector-specific and cross-cutting standards
☐ Establish traceable documentation for auditability

Tip: A structured DMA supports both ESRS and VSME—and helps define KPIs with strategic relevance.

If preparing a VSME report:

☐ Use simplified templates aligned with the latest VSME guidance
☐ Ensure disclosures demonstrate efficiency and transparency with limited burden
☐ Highlight sustainability performance in a business-relevant context (e.g. customer or lender expectations)

If building toward IFRS S2 or GFANZ:

☐ Integrate climate-related financial disclosures into mainstream financial filings
☐ Document governance processes for climate-related risks and opportunities
☐ Model transition finance impacts and align with net-zero portfolio expectations if you are part of financial value chains

System and software readiness

To streamline reporting across frameworks:

☐ Use a platform that centralises ESG data and supports framework-specific exports (e.g. ESRS, CDP, TCFD, GRI)
☐ Automate carbon accounting, materiality assessments, and supplier data workflows
☐ Enable collaboration between sustainability, finance, and legal teams inside one system
☐ Choose a solution with embedded guidance for evolving frameworks and audit readiness. Position Green supports all of the above—so your team can focus on strategy, not admin.

Position Green: Putting your compliance ahead of frameworks

Compliance can feel like a endless web of complexity, but working with us, you’ll have the support of a software that over 750 sustainability professionals use to achieve compliance excellence, regardless of the frameworks they are working with.

Getting these core elements in place today ensures you’re prepared for both convergence and complexity, and always in a position to strategically act to your data. But what do you need in your ESG software to ensure you’re ready to adapt to compliance on a dime? Check out our ESG software buyer’s guide to find out!

Download the free guide

Mikael Sundström

Director

Position Green

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