Beyond Omnibus & Co.: The Substantive Challenges Of Non‑Financial Reporting In Practice

The current debate on non‑financial reporting is strongly shaped by regulatory adjustments. In particular, the European Union (EU) Omnibus package (effective 18 March 2026) has led many companies to expect that sustainability reporting will become easier in the future. In practice, however, it becomes apparent that challenges do not arise from regulation itself in isolation, but are largely driven by issues related to operational implementation.

One major obstacle is the availability of reliable data. This becomes evident, for example, in the application of the EU Taxonomy. For certain activities, a vulnerability or climate risk assessment is required in order for an activity to be classified as taxonomy‑eligible at all. These assessments are methodologically demanding, and go far beyond traditional reporting processes, especially as the practical approach to conducting such assessments has so far only been specified to a limited extent.

In addition to data availability, the structure of reporting itself represents a further challenge, particularly for corporate groups with multiple and diverse business models. The existing regulatory frameworks deliberately allow flexibility in the design of the non‑financial statement. However, concrete guidance is often lacking on how sustainability topics should be structured and presented across business areas. Without a clear conceptual reporting model, there is a risk of an unclear report structure and inconsistent disclosures.

The extensive data collection required further complicates implementation, and presents a particular challenge to corporate groups. Non‑financial reporting largely depends on effective communication and process structures, as well as on a clear allocation of responsibilities. Different organisational structures, divergent understandings of data, and heterogeneous internal processes can complicate approaches to reporting. Also, the relevance of non‑financial reporting is often underestimated, which can further hinder cooperation across the group.

At the same time, developments are occurring that facilitate practical implementation. An increasingly permitted top‑down approach to the materiality assessment is perceived in practice as a significant relief. Sharing core business activities and strategically relevant topics, and using these as a basis to identify relevant impacts, risks, and opportunities increases efficiency and simplifies the identification process. The targeted use of artificial intelligence, for example, in the collection of potential impacts, risks, and opportunities can complement the analysis, provided the substantive assessment remains the responsibility of the company itself.

Overall, it is evident that the main challenges of non‑financial reporting are not determined solely by regulatory detail, but frequently lie in the practical design of processes and workflows, as well as in the limited availability of suitable data.