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Article

4 Jun 2025

Author:
PensionsEurope

EU: PensionsEurope warns Omnibus poses serious risk to quantity and quality of ESG data available to investors for informed decision-making

"PensionsEurope’s Position Paper on the European Commission’s Omnibus Simplification Proposal"

[...] However, any simplification should be carefully balanced to ensure that material sustainability information on risks, opportunities, and impacts—critical to informed investor decision-making—is preserved. Accordingly, the Omnibus package should aim to streamline regulatory requirements, eliminate immaterial data, and refocus reporting on relevance and clarity. Indeed, pension funds, as institutional investors, place a high value on companies' transparency and reporting regarding their sustainability impact. Comparable data is necessary for pension funds to make informed investment choices. To manage sustainability risks and accomplish sustainability goals, pension funds need data when choosing which companies to include in their portfolios. In addition, engagement is based on sustainability reporting. [...]

The European Commission’s proposal to significantly reduce the scope of the CSRD — limiting applicability to companies with more than 1,000 employees and either a turnover exceeding €50 million or a balance sheet total above €25 million — could relieve certain reporting burdens. However, this change would exclude approximately 80% of current in-scope entities, posing a serious risk to the quantity and quality of ESG data available to investors for informed decision-making. [...] PensionsEurope therefore opposes any further increase to the employee threshold of 1000 employees, as it would begin to undermine the availability of ESG data across broader segments of institutional portfolios. [...]

On the contrary, PensionsEurope is concerned with the removal of the civil liability regime in the CSDDD. The regime provides international businesses and investors with a European approach, even though it does not completely harmonize liability laws. The proposal would lead to more room for divergent national approaches. [...]

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