1. Voluntary reporting
The Omnibus proposal, apart from reducing the scope of mandatory reporting by 80% –i.e. CSRD remaining mandatory only for companies with more than 1.000 employees or revenue of more than 50 mn euros net turnover- it also points to a new simplified path regarding sustainability reporting: the VSME (Voluntary Sustainability Reporting Standard for non–listed SMEs) (www.vsme.gr). The VSME has been introduced by the European Financial Reporting Advisory Group (EFRAG) since December 2024 -offering micro, small and medium-sized businesses a streamlined framework for sustainability reporting. However, its inclusion in the Omnibus package positioned VSME as the proposed alternative for companies no longer under the CSRD. Furthermore, since the VSME and the European Sustainability Reporting Standards (ESRS) are aligned, businesses can start their sustainability journey by the VSME and always step up to the CSRD later, if requirements or stakeholder demands change.
2. Choosing the right reporting framework
The Omnibus proposal gives companies more flexibility in how they approach ΕSG reporting, as they now have three main paths forward:
Α. Mandatory CSRD: Companies remaining in scope,must continue aligning with CSRD requirements. If a company reports under the CSRD, it needs to follow the ESRS.
Reports are typically structured into four (4) key sections:
- General disclosures (ESRS 2) – including company profile, governance strategy and the double materiality assessment,
- Environmental topics (ESRS 1-5) – such as climate change, pollution, water use, circular economy and biodiversity,
- Social topics (ESRS S1-4) – including workforce conditions, diversity and inclusion, human rights and community impact,
- Governance topics (ESRS G1) – including anti-corruption, board structure, executive pay, and risk management.
Each topic must include disclosures on policies, targets, action plans and performance metrics.
CSRD reports are detailed, data-heavy and supported by external assurance, so it is important to build cross functional collaboration and robust data systems early on.
Β. Voluntary CSRD: Μid-sized companies committed to sustainability are choosing to stay on track, recognizing the competitive and financial advantages of CSRD alignment.
C. VSME adoption: Smaller businesses can turn to the VSME, a practical proportional alternative designed to keep ESG reporting structured. Under the VSME, the structure is standardized, including two levels of detail, depending on the chosen module:
I. Basic Module
It is high-level overview covering of the sustainability status of the company including:
a. General company information,
b. Environmental performance (energy use, GHG emissions, waste management),
c. Social performance (workforce structure, wages, diversity and safety),
d. Governance (anti-corruption and compliance measures).
The module is typically structured as a short, standalone ESG statement, often 5-10 pages, focused on basic KPI’s (Key Performance Indicators), policies and outcomes.
II. Comprehensive Module
It expands on the Basic Module with deeper disclosures on:
a. Business strategy and risk management,
b. GHG reduction targets and climate transition plans,
c. Detailed social and human rights policies,
d. Sector – specific ESG considerations.
This report may mirror the structure of a simplified CSRD report. Companies can break it into clear sections by topic and use narrative plus quantitative data to communicate progress.
If a company choses the Comprehensive Module for its ESG reporting, it must also include the Basic Module.
Regardless of framework, efficient ESG structure is about clarity, consistency and relevance. The company should be transparent about what it is tracking and why, should explain its methodology and show progress over time, ideally with year-on-year comparisons.
The optimum choice of framework for a company depends on the industry, growth plans and stakeholder expectations. For companies that want to stay proactive, the VSME offers a clear and scalable path forward.
3. Conclusion
Voluntary ESG reporting is quickly becoming a meaningful differentiator in today’s market. In a recent 2025 Post-Omnibus Market Pulse Report (www.coolset.com) based on insights from over 250 mid-market and enterprise organizations, 90% claim they plan to continue ESG reporting, even if it’s no longer legally required. The Omnibus proposal may delay or reduce mandatory ΕSG reporting, but it won’t change the growing demand for structured and reliable ESG data. By collecting, identifying and managing reliable ESG data, it becomes a valuable instrument of managing risks, increasing operational efficiency and staying competitive in a world where sustainability is an increasingly valuable business asset! Companies that recognize the value of proactive sustainability management will be better positioned for the future, whether new regulations emerge or not. On the other hand, companies that step back from ESG reporting, risk being viewed as unprepared or lacking transparency. As voluntary disclosure will gradually become the norm, the absence of such disclosures may raise doubts about a company’s credibility and long-term readiness.
In reality, the question is not whether – after the “omnibus era” – ΕSG reporting is still obligatory or not. The real question is whether companies can afford taking the “business risk” to… ignore it!
Μaria El. Stefanaki
(LLM, Cambridge University)
ΕSG Officer
