Using CSRD test reports strategically: The EU Omnibus as an opportunity
With Regulation (EU) 2026/470, the EU has finally adopted the Omnibus I package: since March 18, 2026, a new, combined threshold applies to the CSRD reporting obligation: it affects companies with more than 1,000 employees and more than 450 million euros in revenue. Companies below this threshold can report voluntarily under the VS(ME) standard.
Why CSRD test reports are a strategic advantage
Companies that start implementation early lay the groundwork for robust processes, consistent data quality, early risk management, and long-term strategic positioning. Conducting the double materiality assessment and a structured gap analysis are key steps here, with particular focus on identifying and prioritizing relevant topics and risks. Climate risks in particular are moving increasingly into focus, not only in the context of the CSRD, but also as a key decision criterion for customers, banks, and insurers.
The CSRD data points (ESRS) also provide a comprehensive foundation for all kinds of other standards and customer requests, such as CDP, EcoVadis, and SAQ 5, and can be extended with company-specific topics as needed.
Companies already in the middle of implementation should keep consistently pursuing the path they've chosen, not only to avoid the costs of stopping and restarting, but also to make effective use of the know-how already invested. The time gained offers the chance to consolidate existing structures, deliberately advance automation and data quality in key focus areas, and further professionalize internal processes. The resulting solid data foundation can then serve as the basis for strategic decisions that turn sustainability topics into business value.
Six steps for structured preparation
1. Clarify responsibilities and establish internal processes
Before data collection and report preparation begin, it is essential to clearly assign roles and responsibilities. It should be clearly defined who is responsible for data collection, report consolidation and drafting, as well as quality assurance and, if applicable, design.
2. Identify, collect, and structure relevant data
Identify relevant data early on, recognize existing gaps in data sources, and derive targeted measures for future data collection.
3. Set up the reporting process in a structured way
The time gained through the Omnibus decision makes it possible to build processes without time pressure, test systems, and clearly define responsibilities.
4. Control the data collection process effectively
Especially in international organizations with multiple locations, centrally managing data returns is crucial to ensure consistency and completeness, and to avoid duplication of work and delays.
5. Integrate financial and sustainability data
The CSRD requires high-quality and year-over-year comparable data—both financial and non-financial. A clean data structure and thorough documentation help prevent follow-up questions from auditors.
6. Use test reports as a strategic tool
A CSRD test report uncovers optimization potential early and enables targeted development of processes. This not only improves report quality in the long run but also significantly reduces the effort for future reporting obligations. Additionally, it helps avoid penalties due to delays or non-compliance.
Insights from implementation
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