The EU’s Omnibus package, adopted by the European Parliament on 13 November 2025, aims to make sustainability requirements simpler and more manageable for businesses.
For non-listed small and medium-sized enterprises (SMEs), this does not mean fewer expectations, but more realistic processes – and fewer, more concrete data points.
Reporting requirements will still arise indirectly through the value chains of larger customers and through banks, which from 1 July 2025 have been required to integrate ESG considerations into credit assessments and risk management.
In practice, this means that SMEs will be asked to provide fewer, but higher-quality data points. Companies should therefore focus on collecting information that can be reused across customers, suppliers and financial partners.
Start simple – and gradually improve data quality
The indirect impact means that large companies are focusing primarily on the most material ESG data. During a transition period, well-documented estimates may be acceptable, giving SMEs greater flexibility.
The recommendation for SMEs is therefore to start their reporting efforts in a simple but structured way, with the ambition of gradually improving data quality over time.
For listed SMEs, the direct requirements under CSRD still apply.
The Omnibus adjustments mean that the phasing-in period will be extended, and some requirements simplified, but the underlying reporting obligation remains unchanged.
An effective way to approach reporting is to structure data according to the VSME standard and map it to the ESRS requirements. This approach helps avoid duplication of work.
Banks request ESG data based on a risk-based approach
In Denmark, banks have been required since July 2025 to incorporate ESG risks into their credit assessments (L 193). This does not mean full ESG requirements for all companies from day one, but it introduces a risk-based approach, where:
- Industries with high ESG risk are prioritised
- Data requirements are scaled according to materiality
- Data must be usable in risk models.
Banks’ focus on data quality and traceability will increase significantly in the coming years.
At the same time, tools such as the ESG Profile and collaborations with data platforms are intended to make data collection more manageable and easier to reuse across banks, customers and partners.
VSME: The practical and well-designed solution
EFRAG’s VSME standard is a voluntary reporting framework for SMEs that is both practical and easy to implement. It brings together the data points that large customers and banks typically request in a simple and proportionate structure that can be expanded over time.
VSME offers SMEs four clear advantages:
- A common language understood by both customers and banks
- Reusable data without additional work
- A proportionate and manageable framework
- Future-proofing in relation to both CSRD and credit requirements.
VSME therefore provides a strong foundation for companies facing both indirect and direct ESG expectations, and the framework is recommended by the EU for SMEs.
How we can help
At Grant Thornton, we help companies establish a VSME-based data package that quickly prepares them for both banks and customers.
This may include:
- A baseline calculation of emissions (Scope 1 and 2)
- Policies and guidelines
- A compact transition plan
- A reusable data sheet ready for customers and banks
- The option of light-touch audit support.
We always take your business as a starting point and make the process practical, structured and value-creating.