The European reform of sustainability reporting is taking concrete shape. On 21 September 2026, both the revised European Sustainability Reporting Standards (ESRS) and the new Voluntary Sustainability Reporting Standard (VS) were published in the Official Journal of the European Union. Both standards apply to financial years beginning on or after 1 January 2027.
The reform narrows the scope of mandatory reporting, simplifies the standards and establishes a clearer framework for the exchange of sustainability information across value chains.
CSRD: a significantly narrower scope
The Corporate Sustainability Reporting Directive (CSRD) determines which undertakings are required to disclose sustainability information. Under the Omnibus I package, mandatory reporting is largely restricted to undertakings with more than 1,000 employees and net turnover exceeding €450 million. Parent undertakings are subject to consolidated sustainability reporting where their group exceeds both thresholds on a consolidated basis.
In Belgium, the original CSRD was transposed into national law by the Act of 2 December 2024. The new Omnibus amendments have yet to be transposed into Belgian law, with a transposition deadline of 19 March 2027.
Two new sustainability reporting standards
The European Commission has further implemented the reform through two delegated regulations, building on EFRAG’s technical work.
Revised ESRS – mandatory reporting
The ESRS specify the sustainability information that undertakings within the scope of the CSRD must disclose. The revision reduces the number of mandatory data points by more than 60%, simplifies materiality assessments and places greater emphasis on relevant information.
The principle of double materiality is maintained: undertakings report both on their impacts on people and the environment and on the financial risks and opportunities arising from sustainability matters.
New VS – voluntary reporting
The new VS builds on the VSME, the voluntary sustainability reporting standard for SMEs developed by EFRAG and provides a simplified, harmonised approach for undertakings outside the scope of mandatory CSRD reporting, particularly those with up to 1,000 employees.
The standard comprises a Basic Module and a Comprehensive Module, covering information on environmental matters, employees and governance, among other topics. The reporting requirements have been further simplified, with each data point clearly identified as necessary, necessary if applicable, voluntary or relevant for sector-specific reporting.
Application of the VS remains voluntary.
Value chain cap: limiting mandatory information requests
An important development is the introduction of the value chain cap.
Undertakings subject to the CSRD may need sustainability information from suppliers, distribution partners and other undertakings in their value chains for their own sustainability reporting.
The value chain cap limits the information they may require for this purpose from undertakings with an average of no more than 1,000 employees. The limit is defined by a selection of data points from the VS, set out in Annex II to the Regulation. A more limited set applies to undertakings with no more than ten employees.
Additional information requests remain possible, but undertakings have the right to refuse to provide information exceeding this limit when requested for CSRD reporting purposes.
The cap does not apply to requests made for other purposes, such as financing, risk assessment or insurance underwriting. However, the European Commission explicitly encourages financial institutions, including insurers, to limit such requests as far as possible to the information covered by the VS.
Relevance for insurance brokers
Most insurance brokers fall outside the scope of mandatory CSRD reporting but form part of insurers’ value chains. In this context, the VS and the value chain cap provide a common reference framework and limit the information that may be required for CSRD reporting purposes.
Their relevance extends beyond brokers’ own reporting. In providing services to corporate clients, structured sustainability information can also contribute to a better understanding of risks, prevention and insurability. The ESRS and VS can provide a common information basis for dialogue between undertakings, brokers and insurers.
The European reform thus shifts the emphasis from extensive reporting obligations towards more proportionate, comparable and usable sustainability information.
