I spent two whole days (June 3-4, 2025) at SEG Investor Relations Congress. Apart from the excellent program and great discussions (the best one was about building relationships with various investor groups, led on the first day by SEG President Dr. Mirosław Kachniewski), the most interesting part for me was a series of individual conversations with company representatives. We talked about what did and did not work in the first year of reporting in accordance with ESRS. On June 3, I also participated online in a round table organized by Frank Bold for MEPs and government representatives negotiating Omnibus. During this meeting, a dozen or so representatives of companies and investors from across Europe shared their experiences and tips on what should and should not be changed in the regulations. Below, I will try to summarize the conclusions from both events.
What didn't work:
- Cooperation with auditors. Almost everyone complained that auditors approached ESRS as a compliance system, when they should have treated it as a true and fair presentation system. ESRS are reporting standards, not a checklist of data points that need to be „ticked off.” This complaint was just as common among my Polish interviewees as it was among European companies.
- Disproportionate and delayed certification standard. This, of course, only applies to our Polish KSUA 3002PL. It was only issued in the middle of the reporting season, which meant that many auditors either started their work very late or had to repeat some of the procedures they had already carried out. What is more, most of my interlocutors claim that the Polish standard is closer to reasonable than limited assurance.
- Difficult language and unclear standards. Some necessary definitions could not be found in the ESRS, and many parts of it are written in a convoluted manner.
- Lack of tools. Most reporting support tools did not exist in mid-2024 when companies began working on their reports, or they had very limited functionality, often boiling down to a simple GHG emissions calculator. Today, the situation is better, but we are talking about the experiences of a completed reporting cycle.
What worked:
- Enormous commitment from teams. Everyone mentioned not only those responsible for sustainable development, but also cooperation within the organization with people dealing with risk, finance, purchasing, product, human resources, and all other issues.
- Collecting data from the value chain. Very often, my interlocutors mentioned that this anticipated nightmare turned out to be a pleasant stroll. This was mainly because it concerned almost exclusively the calculation of GHG emissions in scope 3, which could be estimated in the absence of data from external entities. Companies advanced in sustainable development management, in turn, used only those metrics in their entity-specific disclosures for which they already had a complete set of data.
When considering what should change in the standards themselves and in the legal system as a result of the Omnibus, it is worth taking into account the actual experiences of companies with the reporting process. And when preparing for the changes, it is also important to remember that the Omnibus itself does not halt the dynamic changes in the world around us.
Such changes certainly include the expectations of Norges Bank Investment Management (NBIM), the world's largest fund managing assets worth over $1.5 trillion and investing in more than 9,000 companies. NBIM clearly communicates that it expects companies to actively apply due diligence processes, calculating and reporting GHG emissions, establishing and implementing decarbonization targets, implementing climate transition plans, applying TNFD recommendations to assess and manage environmental impact, and transparent reporting in accordance with recognized reporting standards.
Regardless of what politicians may come up with in terms of sustainable development regulations, NBIM, as a heavyweight player among investors, meticulously holds its portfolio companies accountable for meeting its expectations. Take a look at their latest report on climate and the environment 😊
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