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The 13th edition of Tennaxia's annual study on corporate non-financial reporting practices is being published in an unprecedented regulatory context. Just as the Corporate Sustainability Reporting Directive (CSRD) was set to profoundly change the sustainability landscape, the unexpected introduction of the Omnibus Directive in early 2025 has reshuffled the deck. By postponing the reporting obligation for the second wave of companies to 2028 (based on 2027 data) and proposing a possible increase in the submission threshold (to 1,000 employees, up from 250 initially), Omnibus has created a period of uncertainty.
However, rather than seeing a general decline, the analysis reveals a striking fact: non-financial reporting is doing surprisingly well. Despite the temptation to take a step back and the prevailing gloom, there is now a consensus within organizations on the usefulness of ESG reporting, which is now firmly established in performance management and business model resilience.
Our study, conducted among more than 200 companies of all sizes and sectors, captures this paradoxical dynamic. It shows that the foundations laid by ESG are now solid enough to go beyond the scope of simple regulatory constraints, transforming transparency into a real strategic lever. The results were published at a conference held at the Produrable 2025 trade show.
ESG, a pillar of resilience stronger than regulation
The most dramatic impact of Omnibus is visible among companies that would potentially no longer be subject to the CSRD. Far from expressing relief, an overwhelming majority of them (83%) said they would still produce a voluntary ESG report. This persistence, mainly oriented towards the VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs) framework, confirms that the value of non-financial information far exceeds its legal requirement.
The regulatory setback has thus highlighted the true nature of the CSRD: an opportunity for strategic transformation. For 67% of companies, the CSRD is primarily seen as a means of rethinking the company's business model, a sharp increase from the previous year (57%). This strategic advantage far outweighs perceptions of the directive as a human (62%) or financial (32%) burden.
The companies surveyed, whether subject to reporting requirements or not, have recognized that the reporting exercise enables them to:
- Identify and anticipate medium- and long-term risks in concrete terms to ensure the sustainability of the business model.
- To improve attractiveness to stakeholders, particularly customers, banks, and investors. In fact, 89% of companies already use their sustainability data to respond to their requests.
- Better manage company performance
This deliberate shift can also be explained by the high level of dissatisfaction among companies that have already invested time and resources. Among those that would no longer be subject to the regulations, 71% view the Omnibus amendment as rather negative, criticizing the instability it creates for the future of CSR (89% of negative points) and the discouragement it causes for those who had already initiated a strategy (60%).
Governance: a profound restructuring and new key functions
Preparation for the CSRD has led to accelerated internal restructuring. In one year, the percentage of companies that have implemented dedicated CSR governance has jumped from 59% to 84%. Specific governance is considered essential for managing such a cross-functional project, involving multiple functions and entities.
While project management remains largely the responsibility of CSR departments (65%), the study highlights two major developments in the involvement of other departments:
- The Chief Financial Officer (CFO): CFOs are now almost always involved (85%), and 56% of companies have noticed a greater level of involvement on their part with the CSRD. This involvement is logical, as CFOs' expertise in reporting, auditing, and translating ESG data into financial data is essential.
- The Purchasing Department: This is the biggest surprise in this edition. The involvement of the Purchasing function has increased from just 7% in 2024 to 63% in 2025. This paradigm shift reflects companies' understanding that the CSRD's Impact, Risk, and Opportunity (IRO) analysis must cover the entire value chain, making purchasing expertise indispensable for analyzing the upstream chain and reporting information from suppliers.
Furthermore, this increase in importance is reflected in more regular reporting: companies now report ESG information to management more frequently, with the majority opting for quarterly reporting. This signals a greater awareness of the need to manage this data on an operational basis, rather than just annually.
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The data challenge and the carbon priority
Despite progress in governance, the study confirms that the main stumbling block for CSRD remains data. The difficulties most often cited spontaneously by respondents are related to data (volume and definitions), lack of human/financial resources, and lack of understanding of the texts.
Regarding the first wave of publication (2025 on 2024 data), 46% of companies were unable to collect all the required indicators, and 83% had to prioritize. Worse still, 25% published information whose definitions or calculation methods did not comply with regulatory requirements.
This difficulty has repercussions on audits, where the first issue raised by auditors (for 29% of audited companies) is the quality of quantitative data. The lack of data governance is an aggravating factor, since 35% of companies that have already published data still do not have a dedicated team in place.
Among the requirements, companies quickly identified the major issues. The three ESRS (European Sustainability Reporting Standards) most widely considered to be material for the financial year are, unsurprisingly:
- ESRS E1: Climate change (98%).
- ESRS G1: Conduct of business (97%).
- ESRS S1: Company personnel (93%).
The focus on climate change is particularly noteworthy. Measuring carbon footprints is the second most common structural measure after the implementation of governance. The proportion of companies measuring their Scope 3 (indirect emissions) remains stable at 90%. Above all, 66% of companies have now defined a trajectory for reducing their emissions, two-thirds of which are compatible with the 1.5°C warming target, an alignment that has made significant progress in one year.
The Omnibus dilemma: a costly break
The Omnibus is a double-edged sword. While the main advantage identified by companies is the additional time allowed to better prepare (62%, particularly to acquire the appropriate tools and organize themselves internally), the revision has led to a disengagement from certain functions for half of the companies.
The departments that have seen the most disengagement are the Administrative and Financial Department (63% disengagement) and the General Management Department (51%). For these functions, uncertainty has been used as a pretext to backtrack and return to operational emergencies, leaving it up to the Commission to clarify future requirements. This setback is all the more frustrating as it renders costs already incurred (training, tools, recruitment) obsolete and slows down the momentum of the transformation that has been initiated.
Conclusion: the sustainability of a strategic commitment
Tennaxia's 2025 study offers crucial insight: while the CSRD has been slowed down by Omnibus, the need for non-financial reporting is now considered a strategic and financial imperative.
The regulatory setback has shown that ESG has built a sufficiently solid foundation for the majority of companies to continue the process voluntarily, valuing resilience and market attractiveness over mere compliance. The question of format thus becomes almost incidental.
Nevertheless, pressure on data quality and reliability will only increase, particularly with the growing involvement of auditors and the central issue of traceability of impacts in the value chain. Companies must take advantage of the additional time to consolidate their data governance and equip themselves adequately, without waiting for the Omnibus bill to be finalized.
For detailed analyses, sector comparisons, and comprehensive information on the specific challenges of data collection and carbon management practices, download the full study.
To obtain all the data and guidance on preparing for the CSRD in this context of uncertainty, download the full 13th edition of the Tennaxia study!