EXECUTIVE SUMMARY
When sustainability rules change, it is reasonable to ask which work still deserves time and money. A reporting project may need to be smaller. A planned investment may need a different timetable. Some data requests may no longer be justified. Reviewing those commitments is part of good management.
We would start with the decisions the business still has to make: where to invest, which suppliers to rely on, how to protect operations and what to promise customers. Sustainability work earns its place when it gives people better information for those decisions. Its value needs to be demonstrated in the circumstances of the business, with clear assumptions about costs, benefits and uncertainty.
The changes taking effect in 2026 make that discipline especially useful. They give companies a reason to revisit the scope of their programmes, preserve the work that addresses material risks and stop activities that no longer serve a clear purpose.
What the 2026 changes mean
The EU's Omnibus I amendments, adopted in February 2026, narrowed the scope of the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive. They also removed the CSDDD requirement to adopt a climate transition plan. Companies should reassess their position against the amended framework, checking national implementation and the relevant application dates before changing their compliance arrangements.
That reassessment should sit alongside a review of commercial commitments. A customer questionnaire, a lender's information request and a statutory reporting duty have different purposes and legal bases. Treating them as one undifferentiated list makes it difficult to decide what is necessary, what is negotiable and what information the company needs for itself.
Consumer-facing claims need attention too. The EU rules on empowering consumers for the green transition entered into application on 27 September 2026, strengthening protection against misleading environmental claims. For businesses selling to consumers, this brings a practical task: review the wording on products, websites and sales materials against the applicable national rules and the evidence behind each claim.
Our reading of these developments is that companies need a more selective programme, with a clear reason for each activity. A change in reporting scope may justify simplifying a reporting process. Decisions about a flood-exposed site, an unreliable supplier or an unsupported product claim need their own assessment.
Six practical choices
Keep a clear view of what applies
Give each material requirement an owner. Record the entity, activity or product it affects, the date that matters and the decision it requires. For a business operating across several markets, maintain a shared set of core information and add local requirements where they differ.
This can be a manageable register rather than another large reporting exercise. Its usefulness comes from connecting a change in the rules to a person who can act on it. When an interpretation remains uncertain, record the uncertainty and agree what would trigger a new decision.
Put the budget against the work
Review spending by workstream. Identify the work needed to meet an obligation, address an exposure, support a commercial decision or maintain essential capability. Then test its cost, timing and expected benefit. Activities with a weak rationale should be redesigned, reduced or stopped.
External support can help when specialist knowledge is needed for a defined period. A fractional leadership arrangement can also be useful when coordination is needed but a full-time role is not yet justified. Neither arrangement is automatically cheaper or more effective. Compare the total cost, the responsibilities the company must retain and the capability that will remain when the engagement ends.
Make the trade-offs explicit
Finance, procurement, operations and sustainability teams will often see different priorities in the same project. Bring those differences into the decision. A supplier change, for example, may improve traceability while increasing cost or concentrating supply. A resilience investment may have a long payback but protect an operation that is difficult to replace.
We recommend recording the options considered, the assumptions that matter and the reason for the chosen approach. An independent adviser can help challenge those assumptions, but management needs to own the judgement and the consequences.
Keep useful work moving
Separate the parts of a project that depend on a regulatory decision from the parts that already have a business case. Improving the quality of supplier information or checking the condition of a critical asset may remain worthwhile while reporting specifications change.
Use a limited pilot where the evidence is incomplete. Agree what it should establish, how much the business is prepared to spend and what would justify expanding it. This creates room to learn without committing the whole organisation to an approach that has not been tested.
Connect climate analysis to operations
Start with the locations, assets and suppliers whose interruption would matter most. Ask how heat, flooding, water stress or other relevant hazards could affect production, logistics, people and insurance. The assessment should explain the exposure and its limitations at a level that the responsible manager can use.
Then work through the available responses: maintenance, alternative supply, business-continuity arrangements, insurance or investment. Compare their costs and the risks that would remain. Treat scenarios as ways to test decisions under different conditions. Avoid presenting a precise-looking estimate as a certain forecast.
Leave the team able to carry on
A sustainability programme needs people who understand how to use its information in their own work. Procurement needs a workable supplier process. Finance needs assumptions it can examine. Operations needs measures it can implement and maintain.
Make those responsibilities part of the project from the beginning. Where advisers are involved, include working sessions, usable documentation and a clear handover. A useful test at the end is whether the internal team can explain the analysis, update it and make the next decision without starting again.
How to judge the value
Risk reduction
Look for a specific change in exposure or preparedness. Has a critical dependency been addressed? Is there a workable response to an interruption? Record the remaining risk as carefully as the improvement. Completing an assessment alone does not establish that the business is safer.
Operational efficiency
Track the work people actually do. Fewer duplicate requests, clearer ownership and information that can be reused may reduce effort. Compare the result with a documented starting point and include the cost of maintaining the process.
Customer and market requirements
Connect the work to identifiable requirements in a tender, contract or product market. Better evidence may help a company answer a customer's questions or demonstrate compliance. It does not guarantee a contract, and additional data collection should have a proportionate purpose.
Financing decisions
Assess financing benefits against actual offers, contractual terms or documented comparable transactions. Pricing depends on the borrower, lender, instrument and market conditions. A sustainability label alone is not evidence of cheaper finance. Where risk information changes a financing decision, explain how and retain the assumptions behind the comparison.
What to watch as 2027 approaches
As companies prepare their next budgets, the immediate task is to bring their plans into line with the rules and commitments that now apply. Review national implementation of the EU amendments, check consumer-facing environmental claims and confirm which customer or financing requirements remain relevant. Avoid treating a headline about simplification as a complete assessment of the company's position.
The review should also cover changes within the business. A new site, acquisition, supplier or financing arrangement can matter more to the next decision than another general market forecast. Keep the programme responsive to those changes, and make it clear who can alter its scope when the evidence warrants it.
Where to start
For the next management review, bring together the current obligations, the most material exposures and the work already under way. Identify the activities that should continue, those that need to change and those that can stop. Give each decision an owner, a budget where needed and a date for review.
Choose a small number of priorities that the organisation can carry through. Agree what evidence would demonstrate progress and what would cause the team to reconsider. This makes the programme easier to manage and gives leadership a clearer basis for allocating resources.
We help teams connect regulatory requirements with these practical choices across sustainability strategy, reporting and climate risk. If you are reviewing the direction of your programme, tell us which decisions need to move forward. We can help define the work and the expertise it needs.