--- title: "ESG Trends 2026: What Changed in 2025 and What EU Filers Face Next" description: "ESG in 2026 for EU filers: the Omnibus scope reset, what more than 1,000 European sustainability reports actually disclose, and what to prepare this year." image: https://www.fiegenbaum.solutions/hubfs/pexels-cluster-images/7947664.jpg --- [Skip to content](https://www.fiegenbaum.solutions/en/blog/sustainability-esg-2025-metrics-technologies-compliance#main-content) [![Fiegenbaum Solutions Logo](https://www.fiegenbaum.solutions/hubfs/Branding/Fiegenbaum-Solutions_Logo.svg) ![Fiegenbaum Solutions Logo](https://www.fiegenbaum.solutions/hubfs/Branding/Fiegenbaum-Solutions_Logo.svg)](https://www.fiegenbaum.solutions/en/?hsLang=en) - [English](https://www.fiegenbaum.solutions/en/blog/sustainability-esg-2025-metrics-technologies-compliance) - [Deutsch](https://www.fiegenbaum.solutions/blog/jenseits-des-carbon-footprints-was-intelligente-unternehmen-im-jahr-2025-erfassen) - Services - [Climate Risk Assessment](https://www.fiegenbaum.solutions/en/climate-risk-analysis-for-companies) - [VSME Report](https://www.fiegenbaum.solutions/en/vsme-reporting-for-smes) - [ESG Due Diligence VCs & Series A+](https://www.fiegenbaum.solutions/en/esg-due-diligence-vcs-series-a-startups) - [Product Carbon Footprint](https://www.fiegenbaum.solutions/en/product-carbon-footprint-lifecycle-assessment) - [Corporate Carbon Footprint](https://www.fiegenbaum.solutions/en/company-carbon-footprint-methods-tools-best-practice) - Solutions - [Materiality Screening](https://www.fiegenbaum.solutions/en/double-materiality-analysis-definition-process-best-practice#fs-screening) - [Atlas](https://atlas.fiegenbaum.solutions/en) - [Load Profile Check](https://atlas.fiegenbaum.solutions/en/lastgang-check) - [Pricing](https://www.fiegenbaum.solutions/en/esg-climate-consulting-fixed-prices-carbon-footprint-vsme-due-diligence-climate-risk) - [About me](https://www.fiegenbaum.solutions/en/about-me) - [Blog](https://www.fiegenbaum.solutions/en/blog) - [Contact](https://www.fiegenbaum.solutions/en/contact) ###### 6 min read # ESG Trends 2026: What Changed in 2025 and What EU Companies Face Next By: [Johannes Fiegenbaum](https://www.fiegenbaum.solutions/en/blog/author/johannes-fiegenbaum) on 5/23/25, 11:12 AM · Last updated October 11, 2026 [Climate Policy & Green Claims](https://www.fiegenbaum.solutions/en/blog/tag/climate-policy-green-claims) [ESG Strategy & Materiality](https://www.fiegenbaum.solutions/en/blog/tag/esg-strategy-materiality) ![Flat lay of business plans, reports and a magnifying glass](https://www.fiegenbaum.solutions/hubfs/pexels-cluster-images/7947664.jpg) ESG reporting in Europe did not get bigger in 2025. It got narrower, later and more contested. The EU Omnibus package rewrote who has to report and when, the CS3D due diligence regime was cut back, and the technology debate moved from ambition to a plainer question: can the data actually be extracted from a filed report? This page is a year pivot for EU filers: what changed in 2025, what more than 1,000 European sustainability reports show when read as data rather than as prose, and what 2026 requires. If you came for the metric definitions themselves, my list of [seven key ESG metrics](https://www.fiegenbaum.solutions/en/blog/7-key-esg-metrics-2025?hsLang=en) covers that ground in full. *Last reviewed: 4 September 2026.* ## What Changed in 2025: Omnibus, Deferral and Divergence The single most consequential development for EU filers was the Omnibus revision of the [CSRD](https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en). Reporting duties now apply to companies above both thresholds, more than 1,000 employees and more than 450 million euro net turnover, for financial years starting in 2027, with first reports due in 2028. The staggered wave logic that dominated planning for three years no longer describes reality: what used to be CSRD wave 2 has largely dissolved into a single threshold test. CSDDD was narrowed in parallel to groups above 5,000 employees and 1.5 billion euro turnover, and its Article 22 obligation to put a transition plan into effect was deleted. | What changed in 2025 | What it requires in 2026 | | --- | --- | | CSRD thresholds raised to 1,000 employees and 450 million euro turnover | Re-run the scope test before budgeting a reporting project, many prior wave 2 companies are out | | First affected financial years start in 2027 | Treat 2026 as a data year, not a filing year | | CSDDD narrowed, Article 22 transition plan duty deleted | Expect due diligence and value chain demands through contracts and financing instead | | VSME confirmed as the voluntary standard with a value chain cap | Answer supplier requests with one VSME dataset rather than bespoke questionnaires | ## What More Than 1,000 European Sustainability Reports Actually Disclose Most trend pieces quote what companies announced. I read what they filed. Across the European CSRD and ESRS reports in my extraction pool, covering the 2024 and 2025 reporting years, 67 percent carry all three emission scopes in machine readable form. A further 14 percent contain no extractable scope data at all, despite a filed sustainability report. Looking only at more than 1,000 reports from the 2024 and 2025 cycles, the quality picture gets sharper. About 8 percent of reports that carry a Scope 3 figure show it as smaller than Scope 1 or Scope 2, which is a methodological red flag, since Scope 3 is typically five to ten times larger. Data as of September 2026. My position after reading that pool: compliance without a time series is a photograph, not a steering instrument. A report that cannot be compared with last year cannot inform a decarbonisation decision, and an auditor will find that out faster than a stakeholder will. One example from practice. An industrial manufacturer with roughly 900 employees in southern Germany published a complete looking report whose Scope 3 covered purchased goods and business travel only. The number was not wrong, it was incomplete in a way no reader could see, because the boundary was never stated. ## Technology and Data: What Actually Held Up in Practice Of the technologies that dominated ESG conference agendas, one category survived contact with a reporting deadline: unglamorous data plumbing. Extraction from ERP and utility systems, emission factor management with versioning, and a documented audit trail from source record to disclosed figure. These changed how data is collected. Ledger based ESG verification and sensor dashboards mostly did not, because the binding constraint was never trust in a number, it was that the number did not exist yet. [Scope 3 and value chain data](https://www.fiegenbaum.solutions/en/blog/science-based-targets-initiative-sbti-guide-eu-companies?hsLang=en) remain the bottleneck. Spend based estimates get a first figure on the page quickly and then stop improving, because the factor, not the activity, drives the result. Moving the largest categories to activity data is the only step that makes a year on year series meaningful. A point from building reporting software rather than from vendor briefings: market based Scope 2 accounting is methodologically correct and still fails in tool practice more often than any other method, because it depends on contractual instruments that companies cannot evidence per site and per year. If the certificates are not documented, the location based figure is the honest one. A logistics group with about 400 employees in Austria spent one reporting cycle on a sensor pilot and the next on supplier master data. Only the second one changed the report. ## What to Prepare for in 2026: Wave 2, VSME and Transition Plans 2026 is the year to build the dataset that the 2027 financial year will consume. A short checklist: - Re-run the scope test against the Omnibus thresholds, subsidiaries included, and document the result. - Fix baselines and reporting boundaries now, and give every datapoint one named owner. - Decide between [VSME](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-standard-smes?hsLang=en) and full [ESRS](https://www.fiegenbaum.solutions/en/blog/a-complete-overview-of-esrs-standards-key-reporting-guidelines-for-corporate-sustainability-under-csrd?hsLang=en) for entities that fall out of direct scope but stay in someone else's value chain. - Put the [transition plan](https://www.fiegenbaum.solutions/en/blog/physical-risks-and-transition-risks-how-to-assess-climate-risks?hsLang=en) on a financing footing. Even without the Article 22 duty, lenders price it. - Check every net zero and climate neutral claim against the [Empowering Consumers Directive](https://eur-lex.europa.eu/eli/dir/2024/825/oj), which applies from 27 September 2026 and turns [greenwashing](https://www.fiegenbaum.solutions/en/blog/avoiding-greenwashing-driving-true-sustainability?hsLang=en) into a litigation risk. - Assess whether biodiversity and natural capital are material, and if so start collecting a year early. Investors have shifted their asks in the same direction. Under stewardship code expectations they now want a comparable series, a stated boundary and a transition plan that reconciles with capital expenditure, rather than a broader set of indicators. ## EU and US Divergence: Where the SEC Rule Leaves EU Filers The SEC climate disclosure rule is not in force, and the Commission stepped back from defending it in litigation, so there is no federal US reporting duty that mirrors ESRS. For EU subsidiaries of US parents this creates a specific problem rather than a saving. The group has no consolidated climate dataset to hand down, while the European entity still needs one, either directly or because a customer asks for it under the [value chain cap](https://www.fiegenbaum.solutions/en/blog/eu-value-chain-cap-five-gaps-voluntary-standard?hsLang=en). A German subsidiary of a US industrial group, around 600 employees, built its own scope inventory in 2025 for exactly that reason. The group finance system had nothing to give it. If your parent is American, plan the data work locally and do not wait for it to arrive from headquarters. ## Frequently Asked Questions Which companies are still in scope for CSRD after the Omnibus? Companies above both thresholds, more than 1,000 employees and more than 450 million euro net turnover, for financial years starting in 2027. Much of the former wave 2 is no longer directly in scope. When does VSME apply instead of full ESRS? VSME is the voluntary standard for companies outside direct CSRD scope, and it caps what larger filers may demand from value chain partners. Out of scope but receiving questionnaires: answer with VSME. Do transition plans become mandatory, and for whom? The CSDDD duty to put a plan into effect was deleted, and CSDDD now covers only very large groups. In practice the demand returns through lenders, insurers and large customers. What happened to the SEC climate disclosure rule, and does it affect EU filers? It is not in force and is no longer being defended by the Commission. EU subsidiaries of US parents get no group level climate dataset from headquarters and have to build their own. Next step Turn climate risk or ESG data into a decision? In a 30-minute intro call we map where your biggest lever is, with no obligation. [Book an intro call](https://www.fiegenbaum.solutions/en/contact?hsLang=en) ![Johannes Fiegenbaum](https://www.fiegenbaum.solutions/hubfs/Johannes_07-modified.png) ### Johannes Fiegenbaum ESG and sustainability consultant based in Hamburg, specialised in VSME reporting, carbon accounting and climate risk analysis. Works with mid-sized companies, investors and financial institutions, and built the VSME reporting software VSEasy. [More about](https://www.fiegenbaum.solutions/en/about-me?hsLang=en) Related articles ## You may also like ### [VSME EU Omnibus Package 2026: Simplifying CSRD Reporting for SMEs & Large Companies Directive (EU) 2026/470, the "Omnibus I" directive, was published in the Official Journal on 26 February 2026 and has been in force since 18 March 2026. It is settled law, not a ... Read more →](https://www.fiegenbaum.solutions/en/blog/eu-omnibus-package-2025-simplifying-csrd-reporting?hsLang=en) ### [Climate Risk Assessment CSRD Climate Risk Reporting: What EU Companies Must Disclose From 2026 Onwards Read more →](https://www.fiegenbaum.solutions/en/blog/csrd-climate-risk-reporting-companies-2026-eu?hsLang=en) ### [Climate Risk Assessment Physical risks and transition risks: How to assess climate risks Read more →](https://www.fiegenbaum.solutions/en/blog/physical-risks-and-transition-risks-how-to-assess-climate-risks?hsLang=en) ### [Climate Policy & Green Claims Navigating the ESG Backlash: Risks, Opportunities, and Strategies for EU Companies Read more →](https://www.fiegenbaum.solutions/en/blog/navigating-esg-backlash-risks-opportunities-strategies-eu-companies?hsLang=en) ### [Carbon Accounting & Scope 3 VSME Report Example: What a Finished Report Contains, Disclosure by Disclosure Read more →](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-smes-benefits?hsLang=en) ### [Biodiversity & Nature Understanding TNFD: Integrating Nature Risks and Opportunities in Financial Decisions Read more →](https://www.fiegenbaum.solutions/en/blog/understanding-tnfd-integrating-nature-risks-and-opportunities-in-financial-decisions?hsLang=en) ##### Johannes Fiegenbaum Johannes Fiegenbaum I turn climate risk and ESG data into capital and financing decisions. For mid-market companies and investors, data-driven. From Hamburg, for companies across Europe. ##### Tools Tools - [CSRD Materiality Screening](https://www.fiegenbaum.solutions/en/csrd-materiality-screening) ##### Services Services - [Climate Risk Assessment](https://www.fiegenbaum.solutions/en/climate-risk-analysis-for-companies) - [VSME Reporting](https://www.fiegenbaum.solutions/en/vsme-reporting-for-smes) - [Company Carbon Footprint](https://www.fiegenbaum.solutions/en/company-carbon-footprint-methods-tools-best-practice) - [Double Materiality Assessment](https://www.fiegenbaum.solutions/en/double-materiality-analysis-definition-process-best-practice) ##### Fiegenbaum Solutions Fiegenbaum Solutions - [About me](https://www.fiegenbaum.solutions/en/about-me) - [Blog](https://www.fiegenbaum.solutions/en/blog) - [Contact](https://www.fiegenbaum.solutions/en/contact) [![1ftp\_BusinessMember\_Horizontal\_FullColor-250x107-faa8874b-96e3-41e2-bbbe-9303832ac91c](https://www.fiegenbaum.solutions/hubfs/1ftp_BusinessMember_Horizontal_FullColor-250x107-faa8874b-96e3-41e2-bbbe-9303832ac91c.png)](https://www.onepercentfortheplanet.org/) - [Legal Notice](https://www.fiegenbaum.solutions/en/legal-notice) - [Privacy Policy](https://www.fiegenbaum.solutions/en/privacy-policy) © 2026 Fiegenbaum Solutions ```json { "@context" : "https://schema.org", "@type" : "BlogPosting", "author" : { "@type" : "Person", "name" : "Johannes Fiegenbaum", "url" : "https://www.fiegenbaum.solutions/en/blog/author/johannes-fiegenbaum" }, "dateModified" : "2025-05-23T09:12:53.380Z", "datePublished" : "2025-05-23T09:12:43.000Z", "headline" : "ESG Trends 2026: What Changed in 2025 and What EU Filers Face Next", "image" : [ "https://www.fiegenbaum.solutions/hubfs/pexels-cluster-images/7947664.jpg" ], "mainEntityOfPage" : { "@id" : "https://www.fiegenbaum.solutions/en/blog/sustainability-esg-2025-metrics-technologies-compliance", "@type" : "WebPage" }, "publisher" : { "@type" : "Organization", "logo" : { "@type" : "ImageObject", "url" : "https://www.fiegenbaum.solutions/hubfs/FS_Logo.svg" }, "name" : "Fiegenbaum & Cie. GmbH" } } ``` ```json { "@context" : "https://schema.org", "@id" : "https://www.fiegenbaum.solutions/#organization", "@type" : "Organization", "areaServed" : { "@type" : "Place", "name" : "European Union" }, "description" : "Nachhaltigkeitsberatung mit Fokus auf Klimarisikoanalyse, ESG-Reporting (CSRD, VSME) und Climate Tech Investmentberatung.", "employee" : { "@id" : "https://www.fiegenbaum.solutions/#founder" }, "founder" : { "@id" : "https://www.fiegenbaum.solutions/#founder" }, "image" : "https://www.fiegenbaum.solutions/hubfs/Branding/Fiegenbaum-Solutions_Logo.svg", "knowsAbout" : [ "ESG Reporting", "CSRD Compliance", "VSME Standard", "Climate Risk Analysis", "EURO-CORDEX", "CMIP6", "Scope 3 Emissions", "Scenario Analysis", "Sustainability Strategy", "Climate Tech Investment" ], "logo" : { "@type" : "ImageObject", "url" : "https://www.fiegenbaum.solutions/hubfs/Branding/Fiegenbaum-Solutions_Logo.svg" }, "name" : "Fiegenbaum Solutions", "sameAs" : [ "https://www.linkedin.com/in/johannesfiegenbaum/" ], "url" : "https://www.fiegenbaum.solutions" } ``` ```json { "@context" : "https://schema.org", "@id" : "https://www.fiegenbaum.solutions/#founder", "@type" : "Person", "affiliation" : [ { "@type" : "Organization", "description" : "Climate tech angel syndicate (Venture Partner)", "name" : "Climate Insiders", "url" : "https://climateinsiders.com/" } ], "alumniOf" : { "@type" : "Organization", "name" : "Universität Tübingen", "url" : "https://uni-tuebingen.de/" }, "description" : "ESG consultant and climate tech investment advisor based in Hamburg. Specializing in VSME reporting, carbon accounting, and climate risk analysis for mid-sized companies, investors, and financial institutions.", "image" : "https://www.fiegenbaum.solutions/hubfs/Johannes_07-modified.png", "jobTitle" : "ESG Consultant & Climate Tech Investment Advisor | CSRD, VSME & Climate Risk Specialist", "knowsAbout" : [ "CSRD", "VSME", "ESG Reporting", "Climate Risk Analysis", "EU Taxonomy", "TNFD", "Climate Tech Investment", "Sustainability Strategy", "Carbon Accounting", "Article 9 Funds" ], "name" : "Johannes Fiegenbaum", "publishingPrinciples" : "https://www.fiegenbaum.solutions/en/legal-notice#editorial", "sameAs" : [ "https://www.linkedin.com/in/johannesfiegenbaum/" ], "url" : "https://www.fiegenbaum.solutions/ueber-mich", "worksFor" : { "@id" : "https://www.fiegenbaum.solutions/#organization" } } ``` ```json { "@context" : "https://schema.org", "@id" : "https://www.fiegenbaum.solutions/#website", "@type" : "WebSite", "inLanguage" : [ "de-DE", "en-EU" ], "name" : "Fiegenbaum Solutions", "publisher" : { "@id" : "https://www.fiegenbaum.solutions/#organization" }, "url" : "https://www.fiegenbaum.solutions" } ``` ```json { "@context" : "https://schema.org", "@type" : "FAQPage", "mainEntity" : [ { "@type" : "Question", "acceptedAnswer" : { "@type" : "Answer", "text" : "Companies above both thresholds, more than 1,000 employees and more than 450 million euro net turnover, for financial years starting in 2027. Much of the former wave 2 is no longer directly in scope." }, "name" : "Which companies are still in scope for CSRD after the Omnibus?" }, { "@type" : "Question", "acceptedAnswer" : { "@type" : "Answer", "text" : "VSME is the voluntary standard for companies outside direct CSRD scope, and it caps what larger filers may demand from value chain partners. Out of scope but receiving questionnaires: answer with VSME." }, "name" : "When does VSME apply instead of full ESRS?" }, { "@type" : "Question", "acceptedAnswer" : { "@type" : "Answer", "text" : "The CSDDD duty to put a plan into effect was deleted, and CSDDD now covers only very large groups. In practice the demand returns through lenders, insurers and large customers." }, "name" : "Do transition plans become mandatory, and for whom?" }, { "@type" : "Question", "acceptedAnswer" : { "@type" : "Answer", "text" : "It is not in force and is no longer being defended by the Commission. EU subsidiaries of US parents get no group level climate dataset from headquarters and have to build their own." }, "name" : "What happened to the SEC climate disclosure rule, and does it affect EU filers?" } ] } ```