WeAreEurope Position Paper on Omnibus

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‍First, we need to deliver a reform that match companies real needs 

As stated in the survey we conducted in February in France, companies want 3 things out of the reform : 

1. First, they want to keep the promise of 1 unified, universal framework for ESG reporting. Most of european companies are asked with 15 ESG data requests every year : clients, investors, insurance companies, banks, are all demanding data in various forms,  its a nightmare !
2. Secondly, companies want ESG reporting to be less complex and more proportional depending on the size
3. Thirdly, for those who are ready because they invested time and money, they don’t want to do it another time, with new rules‍

Thats why we propose 5 points of reform

• Number 1 : there should be only 1 ESRS referential  
• Number 2 : this referential should be based on double materiality, for all companies because its an anti-greenwashing shield 
• Number 3 : at least 30% of current data points should be made optional (technically its easy, you move them from “i shall report” to “i may report”)
• Number 4 : the voluntary reporting should be the midget brother of the compulsory one
• Number 5 : Audit should be simplified and progressive: for the 1st year it should concern only the double materiality assessment 

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Second point :  lets continue to make ESG cheaper and accessible for all

Before CSRD , ESG was too complicated and expensive for small companies.  Only very large corporations were able to absorb its costs and complexity.  With 50 000 companies concerned, CSRD is creating a full change of scale : In France, where 50% of companies are ready , we saw the massification effect working : 

• Open sources tools, start ups, fuelled by investors and AI are delivering economies of scale every trimester, pushing the consulting market to accessible prices for all : 18 months ago, preparation costs were estimated around 300k euros. Now its 50k euros and by the end of the year we were expecting it to decrease even further‍
• But with omnibus proposal exempting 80pc of companies and delaying with a stop the clock of 2 years, we put this dynamic at risk and will make things more expensive for companies in the end. 

Thats why we insist on 2 points to keep the market force in place :

• 500 employees threshold is the right compromise in our view
• Delay should be limited to 1 year : it will force everyone to deliver a quick reform and bring back stability

3rd element and perhaps the most important  - CSRD can make Europe a global leader in ESG data  

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As for the rest of European policies, we should stop being naive : if Europe has a weak referential, not used by most of the companies, China referential, which is a copycat of CSRD,  will become the norm . China companies will become rapidly world leaders without us.

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Thats why we propose to assume our ambition and align obligations for non european companies with the ones for european companies.

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Conclusion

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Last week, at a Global Compact webinar, 1 500 companies answered the question  “How are you feeling about the current Omnibus?”  70% answered they feel confused, frustrated and disappointed.

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Its not surprising, as everyone know that Omnibus has been finalized in a hurry and without real consultations. Its still time to hear companies and build a better Omnibus . 

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Thats why we are launching next Monday, with the collaboration of 200 organisations in Europe, the first European Survey on companies about CSRD. We will ask them in a neutral way, what they really think and what kind of changes they need and we will bring the results  to the public debate in May. 

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China is doubling us on sustainability. Lets use everything in our power to stop that. Lets make us proud of CSRD, not afraid or ashamed of it.

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