A new survey asked companies across the UK, Germany, France, Belgium, the Netherlands, and Luxembourg that were originally in scope for CSRD — then cut loose by the Omnibus reforms — whether they planned to keep reporting anyway. Nine out of ten said yes. Despite having a legal out, they decided to keep reporting.
Sure, this is a European story, but the reasons behind it are directly relevant to U.S. companies that think they don’t need to worry about mandatory sustainability reporting.
The pressure didn’t go anywhere
The osapiens report Beyond Compliance: Sustainability Reporting After the Omnibus surveyed 403 decision-makers from companies that were originally subject to CSRD. Even after being exempted, the vast majority intend to keep disclosing. Their reasons are instructive for U.S. companies that assume this conversation doesn't apply to them.
If your company has EU operations, a European parent, or enterprise customers subject to CSRD, you're already in their reporting chain, whether you've formalized your disclosures or not. CSRD requires companies to report on their value chain, which means their suppliers. If you're one of them and you can't provide structured sustainability data, you become a gap in someone else's compliance program. That's not a position you want to be in.
Investors still want the data. U.S. capital markets may not have a federal climate disclosure mandate on the immediate horizon, but institutional investors haven't paused their ESG questionnaires in the meantime. MSCI, CDP, EcoVadis, and customer-driven supplier assessments run on their own schedule. If you can't respond to these with credible, structured data, you're at a disadvantage in conversations that affect your cost of capital and your customer relationships.
Your enterprise customers are asking, too. Where regulation falls short, procurement steps in. Companies that can respond to ESG requests with formal sustainability data are easier to work with and harder to replace. Companies that can't are a liability and, increasingly, a reason to look elsewhere.
Early reporting shapes the narrative; late reporting reacts to it. The companies that start now get to define how they talk about their sustainability performance and be a model for their peers. The ones that wait until they're required spend their first cycles playing catch-up, often under less favorable conditions.
Think capability, not compliance
Sustainability reporting isn't primarily a documentation problem. It's a capability problem. Building the infrastructure to report well, including data systems, cross-functional workflows, materiality frameworks, and stakeholder input processes takes 12 to 18 months. The companies struggling most with mandatory disclosure aren't the ones that had bad sustainability programs. They're the ones that waited for legal certainty before building anything.
Think about voluntary reporting as a dry run. Same data. Same structure. Zero regulatory pressure. Every cycle you run before you're required to build something: cleaner data collection, clearer ownership across departments, a sharper sense of where your real gaps are. By the time a mandate arrives, whether through CSRD exposure, California's SB 253 (still working through legal challenges, but not dead), or something else, you're not starting from scratch. You're refining something that already works.
What this looks like for a small team
Voluntary reporting doesn't mean publishing a 60-page PDF and hiring a new department. For an early-stage sustainability team, it means starting where you are.
Pick a framework that maps to the direction regulation is heading. GRI and SASB are the most compatible with ESRS (the standards underlying CSRD) and the most recognized by investors and customers. Starting with either gives you a structure that travels well.
Use what you already have. Energy bills, HR data, waste figures, supplier contracts… most companies have more sustainability-relevant data than they realize. An honest inventory of what exists is a better starting point than waiting until you have everything.
Scope it small, then expand. Pick one material topic and one reporting cycle. Before you collect a single data point, run a gap analysis — map what you currently track against what the relevant ESRS disclosures require, and note where the holes are. Some gaps will be closeable this year with existing systems or a modest process change. Others will require new tooling, vendor data, or internal coordination that realistically lands in the next cycle. Document what you're reporting now, what you're building toward, and why. Then add scope the next time around.
Treat every gap you find as a gift. The biggest value in a voluntary cycle isn't the document you produce. It's discovering that your Scope 3 data is incomplete, or that your governance documentation doesn't exist, before those gaps show up in an audit or a customer questionnaire.
The cost of waiting
The regulatory picture is genuinely uncertain right now: CSRD's scope narrowed with Omnibus, California's timelines are contested, and U.S. federal climate disclosure requirements aren't imminent. It's reasonable to ask whether any of this will actually land.
But the underlying market pressure that drove those regulations hasn't gone anywhere. Investors are still pricing climate risk. Enterprise customers are still asking for supplier data. And CSRD exposure through customers or operating entities doesn't require a U.S. federal rule to be real.
The companies that will handle the next wave of requirements most smoothly are the ones building the infrastructure now. The ones waiting for legal certainty will spend their first mandatory cycles scrambling to build what they should have built already.
You don't need a mandate to start. You need a framework, a realistic scope, and the recognition that this year's voluntary cycle is next year's head start. The 90% already figured that out.
Our Regulatory Readiness Solutions: Whether you’re navigating CSRD in Europe, California’s climate disclosure laws, or emerging EPR requirements, the pressure to keep up with the ever-evolving sustainability landscape is mounting. If you’ve been asked to prepare for new sustainability regulations but aren't sure where to start, you’re not alone. We help companies cut through complexity with a clear roadmap that gets you from where you are to where you need to be. Reach out today.
