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Webinar Q&A

1. Could we see less pressure from companies to align ESG verification with their financial auditors i.e. Big 4?
   
   1. The Omnibus proposal suggests removing the requirement for companies to transition from limited to reasonable assurance for ESG disclosures, but assurance will remain an important part of compliance with the CSRD External assurance at the limited level is still required, and the Commission will also issue assurance guidelines on an accelerated timeline. With changes, some companies may decide to use a smaller assurance firm for CSRD assurance, but they should confirm requirements for authorization of assurance providers in the relevant Member State.    .

2. If the Omnibus is still a proposal, how do Wave 2 companies prepare for changes to FY25 reporting, based on FY24 data?
   
   1. Companies that were subject to reporting requirements in FY25 on FY24 data are still required to comply.  Until the  “Stop the Clock” proposal is approved, companies in Wave 2 should also continue collecting data if they have started those processes. A vote on the delay is  scheduled in Parliament for 1 April, to be followed by the other steps that need to be taken by the Council and Member States.  On the specific data, companies should work to identify those data points that are already proving useful to your business or are included in the VSMEs, and prioritize those.  If an IRO is material, the data points the ESRSs cover are likely useful to your business.   .
      
      For now, we recommend moving forward with a strategic and pragmatic DMA, , look to the current ESRSs a  roadmap, pick your key data guideposts, and continue making progress. 

3. Does Persefoni offer a DMA template?
   
   1. Persefoni partners with Upright to ensure companies have access to their uniquely robust assessment of double materiality. More information about Upright’s double materiality assessment is available here: https://www.uprightproject.com/products/csrd-double-materiality-assessment/

4. How does upright's DMA process incorporate stakeholder input, as it's a key component to the EFRAG-aligned DMA?
   
   1. When producing the DMA for a customer, it is also possible to complement the science-based assessment with stakeholder surveys provided by Upright. That being said, given the ESRS doesn’t mandate companies to actively engage with their stakeholders but states it as optional, stakeholder surveys are optional also in Upright’s approach. We have also completed successful DMAs that have passed assurance (by e.g. big 4 auditors) without stakeholder surveys. 

5. Can you share this case study DMA for us to dive into?
   
   1. You can explore the Upright platform and the example profile that was showcased here.

6. How robust are your methodologies when it comes to tackling E4 - Biodiversity and Ecosystems, because there are many tricky topics like invasive species 
   
   1. There are no specific ESRS standards that the Upright methodology works better or worse for. Regarding biodiversity, one main aspect to consider are the value chain effects that the Upright model captures from the upstream to the downstream based on the value chain effects.

7. As companies continue to report on their material IROs and across their value chain (aligned to CSRD), how are we able to compare the data and analyze whether there are any improvements? Or how they’ve matured?
   
   1. To effectively compare and analyze how companies are improving in reporting their material IROs, it's important to focus on standardized, consistent data. Software tools and/or utilizing machine-readable digital tagging enables easier data extraction and comparison across companies and sectors. Year-over-year analysis, industry benchmarking, and reviewing progress against targets can reveal how companies are maturing in their reporting and risk management

8. What are key changes for non-EU entities in Omnibus? 
   
   1. For non-EU entities, EU Sustainability Omnibus Proposal introduces several proposed changes that could impact whether or not they or their EU subsidiaries remain in scope, when they need to report, and how they should approach their sustainability reporting and due diligence obligations.  Non-EU parent companies that were in scope of the CSRD Article 40a provision requiring reporting in FY28 may also be impacted, as the thresholds also may change.  Both these changes may impact how a non-EU company approaches its overall CSRD strategy. 
      
      1. Higher thresholds for “Large” company reporting: 
         
         1. More than 1,000 employees and either
         2. Over €50 million in net turnover, or
         3. Over €25 million in balance sheet total.
      2. Reduced ESRS data points in the reporting standards, streamlining the reporting process.
      3.  No transition from limited to reasonable assurance
      4. The requirement for machine-readable digital tagging (XBRL) remains but has been postponed until the official digital taxonomy is adopted.
      5. The VSME-based "Value Chain Cap" limits the amount of information that larger companies can request from smaller, out-of-scope suppliers.
      6. The threshold for non-EU parent-level reporting in FY28 would increase from 150M Euro annual turnover in the EU to 450M annual turnover in the EU, with an in-scope subsidiary or branch.

9. Are there SBTs for Social and Governance topics?
   
   1. Science-Based Targets (SBTs) are currently only applicable to climate and environmental objectives, specifically for reducing greenhouse gas (GHG) emissions in alignment with the goals of the Paris Agreement (limiting global warming to 1.5°C or well below 2°C). However, many organizations use the following for S & G goalsetting: UN Guiding Principles on Business and Human Rights (UNGPs); World Benchmarking Alliance (WBA); and Global Reporting Initiative (GRI).