From CSRD Compliance to Competitive Edge

Brett Trainor

Associate Director

Table of Contents

• Market Drivers Remain the Same
• Leveraging Compliance for Value Creation
• How Anthesis Can Help
• Contact Us

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This article explores how Double Materiality outputs can be integrated into enterprise-wide sustainability and impact strategies in a way that mitigates risks and creates value, regardless of your organisation’s CSRD-reporting obligations or timelines.

With changes to the CSRD, many market drivers stay the same

EU Omnibus Update

The EU Sustainability Simplification Omnibus Package, announced on the 26^th of February 2025, introduced some key changes to the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CSDDD), the EU Taxonomy Regulation, and the Carbon Border Adjustment Mechanism (CBAM). A full summary of what happened and what could happen next can be found in our recent article and webinar.

Despite significant changes, Double Materiality remains a key element of the CSRD, meaning that in scope companies must report on both how sustainability affects their business and how they impact people and the environment.

The drivers for corporate action on sustainability have also not changed, despite regulatory shifts. Ultimately it is investors, corporates, and consumers who have heavily steered progress on sustainability to date – the role of regulation is only to provide the standardised methodology and approach to allow comparability.

Adapting CSRD Outputs and Timelines

The original requirements of the CSRD included detailed reporting obligations for in-scope companies, with the required content defined by the European Sustainability Reporting Standards (ESRS). For EU listed companies already reporting to CSRD, there are no delays in the proposed Omnibus package. However, for companies that remain in scope of CSRD but haven’t yet reported, the proposed changes could delay reporting by up to two years, which could provide additional time for companies to prepare and recalibrate.

For companies who have been preparing to publish CSRD-compliant reports in 2025, these changes will likely prompt an adjustment to reporting timelines and approaches. However, if your organisation is working towards your Double Materiality Assessment or has started to close your implementation gaps, Anthesis recommends that you go ahead as planned. If your organisation delays your response and the regulations do not change as expected—or if the legislative process takes longer than anticipated—you could be at risk of non-compliance.

You can achieve greater value than just compliance by pressing forward with a robust double materiality assessment that informs sustainability/impact strategy setting and puts in place effective performance improvement plans that prepare your organisation to respond to stakeholder expectations related to Environmental, Social, and Governance (ESG) initiatives.

Maintaining momentum towards addressing and reporting on material impacts, risks, and opportunities

Many of our clients have been grappling with how to maintain momentum towards sustainability objectives despite changes and a lack of clarity regarding reporting requirements and timelines. While some companies are considering pausing compliance driven efforts, others are curious about how to shift focus back towards managing material impacts, risks, and opportunities (IROs). The good news is that, through your Double Materiality process, your organisation has already identified your most material ESG-related IROs. While waiting to confirm which ESRS datapoints will be in-scope for your company, and when you will need to report, you can proactively integrate these IROs into your wider enterprise risk management approach, as well as your overarching sustainability strategy.

Leveraging compliance outputs for value creation

Instead of simply identifying a long list of required actions to close your identified ESRS gaps, this moment presents a unique opportunity to zoom out and view your IROs more holistically. Indeed, it’s a crucial moment to communicate the wider business case for targeted sustainability investments. Framing actions solely as compliance-driven risks losing the budget or headcount your organisation worked so hard to secure based on the original CSRD timelines. As we await further clarity on the proposed Omnibus Regulations, consider refining your prioritisation approach. Rather than focusing solely on actions based on whether they can close an ESRS reporting gap, expand your prioritisation criteria to include whether actions:

• Align with existing value-creation priorities and your enterprise-strategy
• Close a competitive gap, or cement an already-existing leadership position in the market
• Are valued by other important stakeholder groups (investors, customers, consumers)
• Are cost effective and feasible to implement

Of course, your company’s unique drivers for sustainability will dictate the categories above. Regardless of your unique context, by assessing your ESRS gaps based on a wider range of criteria, you can make the case for immediate actions that create value or mitigate risk. Then, once practical implementation of any changes suggested in the Omnibus become clearer, you can finalise your in-scope ESRS datapoints and an implementation roadmap based on your CSRD-reporting deadlines.

How Anthesis Can Help

Anthesis offers a wide range of sustainability strategy services that can support you in this pivotal moment. Our approach to sustainability strategy can build upon the risk and opportunities identified in your Double Materiality Assessment and will integrate your most significant IROs into a unique strategy framework that aligns with your overarching business objectives.

If you’ve completed your Double Materiality Assessment and are in the process of identifying in-scope ESRS datapoints and your readiness to disclose them, Anthesis’ digital data platform, Mero, can simplify this process. Anthesis can customise Mero based on your in-scope topics and then apply the results of your action prioritisation to produce streamlined reports that support you to make the case for targeted sustainability investments while you await CSRD clarity. Based on your material ESRS topics, our specialised nature, net zero & decarbonisation, & human rights teams can support you to develop programs, set strategies, and improve your performance to meet your disclosure requirements.

If we’ve learned anything over the past few years as sustainability regulations continue to morph and change, a solely compliance-driven approach is typically reactive and subject to changes and updates to requirements. Furthermore, seeing sustainability as primarily an exercise in compliance and disclosure could put your company at risk of greenwashing, greenhushing, or falling prey to the increasing polarisation related to ESG more broadly. As we covered in our recent whitepaper, companies must develop ironclad, business-focused communications that highlight integrated approaches, built on risks and opportunities, that make a business more successful. This approach to sustainability and impact is more resilient, relevant, and long-lasting.

Our team of Advisors would be happy to design a customised approach that meets your compliance requirements and creates real value for your organisation.