Omnibus: How to take advantage of the two year reporting delay

The European Commission’s “stop-the-clock” Omnibus package has introduced a two-year delay for many companies under the Corporate Sustainability Reporting Directive (CSRD). Initially, thousands of large and mid-sized firms would have begun reporting ESG data in 2025–2026; now the second wave of companies has until 2028, and listed SMEs (third wave) until 2029​. In addition, lawmakers plan to raise the CSRD applicability threshold from 250 to 1,000 employees, exempting approximately 80% of companies that were previously in scope​. This dramatic change – part of a broader simplification drive – aims to relieve smaller businesses of compliance burden while EU authorities refine the reporting standards.

Does this mean sustainability can take a back seat? Not if companies are wise. The delay is meant to be a buffer, not a brake. Regulators explicitly intend for firms to use the time to adapt and prepare for the new requirements. In voting through the postponement, EU officials emphasized a pragmatic recalibration – acknowledging challenges in implementation, but urging companies to strengthen their sustainability data infrastructure and reporting capabilities so they’re ready when the rules take full effect​. In short, the clock may have paused, but the sustainability mandate has not disappeared.

Using the delay to your advantage

Far from shirking their ESG efforts, many companies are taking advantage of the extra time to enhance their sustainability readiness. Recent surveys and industry feedback indicate that most firms view this delay not as relief from action, but as a chance to improve their game:

Continuing reporting

A majority of affected businesses plan to press on with sustainability reporting despite the delay. In Coolset’s market analysis of 250+ EU companies, 67% said they will continue preparing CSRD-style reports – with 40% doing so voluntarily (only 27% purely due to remaining legal requirements). 

In fact, 90% of companies plan to keep reporting ESG information in some form, seeing it as “a strategic advantage rather than just a compliance task”. Many large enterprises are proceeding without reporting mandates, and even mid-sized firms below the new threshold are pivoting to voluntary disclosures or the upcoming VSME (voluntary SME standard) to maintain momentum​.

Investing in data and systems

With extra breathing room, companies are upgrading their ESG data infrastructure and processes. Automation and software are being embraced to streamline data collection, perform double materiality assessments, and reduce long-term costs of reporting​. 

We see firms investing in everything from emissions tracking systems to data quality controls, ensuring that when audited reporting is required, their underlying data is robust and audit-ready.

Aligning with global standards: 

Many organizations are using the delay to align their disclosures with other frameworks – such as the new ISSB (IFRS S1/S2) standards, TCFD climate reporting, GRI, or national regulations – which can be done voluntarily now. 

This alignment strategy lets companies refine their ESG narratives and ensure compatibility with multiple regimes. Sustainability consultants recommend treating the CSRD delay as a chance to do a trial run of disclosures and implement broader ESG frameworks. 

For example, by establishing a climate risk reporting process now, a company can simultaneously address CSRD requirements, the ISSB’s climate standard (S2), forthcoming California rules, CDP questionnaires, and the UK’s TCFD-based mandates​. 

Aligning with these standards during the grace period means companies will be ahead of the curve – prepared for mandatory reporting later and already meeting investor expectations globally. It also helps identify gaps early and drive internal improvements before compliance is compulsory.

Engaging stakeholders and building capacity

Rather than go quiet, leading companies are deepening stakeholder engagement during this period. This includes engaging internal stakeholders – training staff across departments on ESG data responsibilities, and strengthening governance around sustainability – as well as external stakeholders like investors, clients, and suppliers. 

The Omnibus delay does not equate to lower expectations from these groups: if anything, stakeholders now expect companies to use the time wisely. In the Coolset survey, 85% of businesses acknowledged that ESG transparency remains important to investors, customers and partners, regardless of regulatory timing. 

Companies are heeding this by continuing regular sustainability communications, soliciting feedback on material topics, and refining their ESG strategies with stakeholder input. For example, sustainability teams are revisiting materiality assessments with broader engagement and ensuring the communication channels between stakeholders on ESG issues are wide open​.

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Preparing on multiple fronts

The best-performing companies are treating the delay as a window of opportunity to allocate resources and prepare properly. They are investing in better systems, upskilling teams, integrating ESG into strategy, and generally making sure that when 2028 arrives, they will not only comply but potentially leverage ESG leadership for competitive advantage.

Potential pitfalls

Not all companies may use the delay wisely. There are some negative behaviors and risks emerging in response to the CSRD’s slower timeline. It’s important to recognize and mitigate these tendencies:

Greenhushing

One concerning trend is greenhushing, essentially the opposite of greenwashing. This is when companies intentionally downplay or silence communication about their sustainability efforts, even if they are making progress. A recent global survey by South Pole found that the majority of companies in 9 out of 14 major sectors are “intentionally decreasing their climate communications,”. 

Greenhushing, however, carries its own risks. Keeping silent can erode stakeholder trust, and it squanders the opportunity to get credit for genuine improvements. Transparency, even if voluntary, tends to be rewarded by the market.

Deprioritizing or delaying action

Another temptation is for companies to deprioritize sustainability initiatives internally because the legal pressure is off in the near term. This could mean cutting ESG budgets, halting hiring of sustainability talent, or pausing climate projects – choices that might save costs now but could severely undermine the company’s readiness and reputation. 

For one, CSRD is still law – 20 out of 27 EU member states had already transposed it, so requirements technically exist even if enforcement is delayed​. A company that halts all preparation could find itself non-compliant (and exposed to legal/reputational risk) if the rules re-emerge sooner than expected or in a stricter form.

Even if no longer mandatory, stopping and restarting ESG programs later can be costlier and more difficult than maintaining a steady effort. There’s also the business risk: companies that view CSRD as a mere burden and drop their efforts now will likely fall behind their competitors, missing out on the efficiencies and goodwill gained by continuing to integrate sustainability. 

Keeping the course: Why preparation pays off

For sustainability leads, CFOs, and consultants advising businesses, the takeaway from this two-year CSRD deferral should be: use the time efficiently. Companies that treat the delay as a gift to strengthen their ESG foundation will be far better off than those who become complacent. Following the points below will help set up your company for success.

Treat ESG as value-adding, not just compliance

The strongest reason to keep ESG reporting alive during the CSRD delay? It delivers business value — with or without a legal obligation. Companies that began preparing for CSRD early have uncovered operational inefficiencies, spotted new risks, and improved how they engage stakeholders. These aren’t theoretical benefits - they’re showing up on the balance sheet.

A sustainability lead at a European firm recently told Trio Advisory: “We’re continuing with CSRD implementation because we see the resilience and strategic alignment it brings.” In other words, reporting isn’t just about compliance - it’s about clarity, direction, and credibility. If you’re looking for better access to capital, a stronger brand, or innovation opportunities, ESG performance can open those doors. The delay doesn’t change that.

Be aware of stakeholder and market signals

The CSRD timeline may have shifted, but your stakeholders haven’t. Banks, investors, and clients are still evaluating companies through an ESG lens. Miss the signal, and you risk missing the opportunity.

A solid sustainability profile could unlock better financing terms, as lenders increasingly assess ESG risk when pricing capital. Major buyers now require ESG disclosures in procurement processes. And investors want hard data on climate risk and governance before committing funds. Without credible ESG reporting - even in a simplified form - you could be filtered out early.

Beyond Europe, mandatory reporting is ramping up in other regions too. California, for example, is rolling out emissions disclosure rules that affect thousands of global companies. If you wait until 2028 to get serious, you’ll already be behind.

Maintain readiness and momentum

Think of it this way: the marathon’s been postponed - but if you stop training, you won’t make it to the finish line.

Companies that disband their ESG teams or shelve reporting tools now will face a steeper hill when CSRD resumes. Lost knowledge, broken processes, and delayed buy-in are difficult (and expensive) to rebuild. Instead, this is the time to refine your controls, improve data quality, and keep your team active - even at a slower pace.

Some companies are using this time to run internal dry-runs of their ESG disclosures, stress-testing their systems without the pressure of public release. This approach reveals gaps, sharpens accountability, and ensures you’re ready - whether for regulators or investors.

Consider voluntary reporting as a strategic move

If your company just slipped out of CSRD scope, don’t let that be the end of your sustainability story. Voluntary reporting - especially through the upcoming VSME standard - can help you stay visible, credible, and connected to the ESG expectations of your ecosystem.

Larger clients will still ask for ESG data. Banks will still screen for sustainability risk. The VSME framework offers a lighter but structured way to report, and it’s aligned with the ESRS. For many mid-market companies, this could be the sweet spot - manageable effort, maximum trust.

Staying active in ESG reporting, even if it’s no longer mandatory, sends a clear message: we’re here to lead, not just to follow.

No time to waste, every reason to act

The CSRD delay doesn’t put sustainability on pause - it gives companies the chance to do it better. This is the time to build smarter ESG systems, strengthen stakeholder engagement, and align with the standards that matter. When reporting becomes mandatory again, the businesses that stayed the course will be prepared - and ahead.

The goal of CSRD remains the same: more transparency, more accountability, and better corporate sustainability. That ambition hasn’t changed, and neither should the momentum.

The companies that keep moving won’t just catch up - they’ll lead.

Need support navigating the CSRD delay or setting up for voluntary ESG reporting? Reach out to Coolset. Let’s keep your momentum going.

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