Sustainability Reporting Standards: Which One to Choose? Núria del Pozo, February 2026

Over the last year, the word Omnibus has been heard loudly, and it has been a decisive moment, among others, for the Corporate Reporting Directive on Sustainability (CSRD). Although the final agreement falls short of the ambition of the initial texts, now at least companies have more clarity to move forward.

What has changed in the final version of the CSRD?

• The revised scope covers companies with more than 1000 employees and a turnover of 450 million euros.
• The exemptions extend to listed subsidiaries and financial holdings, subject to specific conditions related to management participation.
• Companies outside the scope, but that have been required to report under the CSRD this year, will not be required to report for fiscal years 2025 or 2026.
• The review clause provides for the possible need to expand the scope in the future or to establish a simplified reporting regime.
• The revised directive introduces new limits on what affected companies can request from partners with fewer than 1000 employees.
• Requests for information for reporting purposes are limited to the Voluntary SME Standard (VSME).
• This limitation does not apply to the collection of information conducted for due diligence or risk management purposes.

The Council is expected to give its final approval to Omnibus Directive 1 (1) on 24 February. It will enter into force 20 days after its publication in the Official Journal.

The application of the directive implies a significant reduction in the perimeter of companies obliged to report under the European Sustainability Reporting Standards (2) (NEIS) and although there is no exact information on the new universe of companies affected, it is clear that the reduction in the perimeter of these companies will have a significant effect on the direction and impact of the directive.

How have the European Sustainability Reporting Standards (NEIS) changed?

On 3 December, EFRAG presented its technical report to the European Commission on the simplification of the NISS. The new standards substantially reduce and simplify mandatory disclosure requirements and data, making them easier and more accessible, including:
• A shift towards useful information and fair presentation.
• A simplified materiality assessment with clearer guidance.
• Significant proportionality measures and specific implementations for the most difficult areas.
• While the revised standards maintain the overall functionality of the NEIS framework, the significant reduction in data points and the combination of exemptions implies that there is a strong reliance on companies to exercise their judgment in good faith.

It is important to note that, although the number of companies obliged to report in accordance with the CSRD has been reduced, the European Commission recommends that companies – particularly SMEs – continue to report sustainability information on a voluntary basis. To this end, EFRAG has designed Voluntary Sustainability Reporting Standards (VSMEs).

What are Voluntary Sustainability Reporting Standards (VSMEs)?

The voluntary standard is guided by principles designed to make sustainability reporting accessible and valuable.

1. Voluntary adoption: the application of the standard is at the discretion of the SME, not being required by any mandatory legislation.
2. Proportional approach: it adapts to the resources of SMEs, ensuring a manageable effort for sustainability reporting. The development of a single standard also has an impact on the optimisation of companies’ resources as they do not have to respond to different criteria that may be required.
3. Simplicity: aim for clear language and intuitive structure.
4. Modularity: it offers two options (basic module and complete module) to adapt to the capacity of your business, being able to scale the information addressed.
5. European alignment: the standard is consistent with the European Union’s sustainability framework on sustainability, set out through the Corporate Sustainability Reporting Directive (CSRD) and its associated standards.
6. Access and relevance: Helps demonstrate performance to improve access to finance and markets by focusing on essential ESG disclosures.
7. Corporate governance: Emphasizes accountability and transparency in reporting on sustainable practices, aligning with sustainability reporting standards and regulations.
8. Internal management tool: helps manage your own sustainability performance and risks.

This standard offers two reporting options:

• “Basic” module: the fundamental basis
This module provides the essential foundation for companies starting out in sustainability reporting.

• “Complete” module: for in-depth focus
For companies that want to improve their sustainability reporting, the full Module adds 9 additional disclosures to the Basic Module.

This standard represents a new element for companies to consider in the universe of existing sustainability reporting standards. In this context, how does this standard align with other existing and widely integrated standards such as GRI, widely used for the preparation of Non-Financial Information Statements (NFIS) in Spain?

What about the GRI standards then?

EFRAG and GRI have collaborated to build the first set of NEIS. EFRAG adopted the same definition of impact materiality as GRI and leveraged GRI’s expertise. In addition, GRI and EFRAG signed a first Memorandum of Understanding in 2021, and on June 10, 2024, GRI published a statement detailing the impact of CSRD on organizations already using GRI standards. In addition, there is a formal and documented index that describes interoperability between standards, a detailed mapping of information requirements, as well as a conceptual alignment in relation to the concept of materiality.

The voluntary standards have been designed based on the requirements and contents of the NEIS (interoperable with the GRI standard), but with a lower degree of demand, with the aim of making it easier for SMEs to accredit compliance with their sustainability performance as part of the value chain of companies obliged to report in accordance with the CSRD.

So which standard to choose?

• If we are within the scope of the CSRD, we must use the modified NEIS standards.
• For organizations that fall outside the current scope of the CSRD:
  • We can act proactively, anticipating the reporting obligation, being able to use the revised NEIS standards or use voluntary standards (such as VSME or GRI) (3).
  • If we act reactively, we will be at the mercy of disclosures that may be requested from us by business partners, banks, or others.

To learn more about voluntary standards, we invite you to attend our Webinar on “VOLUNTARY SUSTAINABILITY STANDARDS FOR SMES (VSME)” that will take place on March 18, Wednesday at 4:30 p.m.

(1) There are several Omnibus directives, of which Omnibus 1 is the one that affects the CSRD directive.

(2) The NEIS specify how companies must report the information required under the CSRD, establishing data points and indicators to be reported.

(3) The choice of one voluntary standard or another will depend on the casuistry of each company (including elements such as markets in which it operates, interest groups that demand information, or sector of activity).

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