An article by Ariane Hofstetter, board member, responsible for sustainability consulting.
Germany has delivered: On September 3, 2025, the Federal Cabinet approved the government draft for the implementation of the CSRD – largely 1:1 in line with the EU requirements and in accordance with the “Substance Proposal” from Omnibus I (including the 1,000-employee threshold). The Federal Ministry of Justice and Consumer Protection has published the draft and an information paper.
What should be irritating about this!
The Green Deal was never just about emissions policy. Its goal was to strengthen competitiveness and make companies more resilient. The Financial Times summarizes the current situation in a very readable way – between relief on the one hand and the risk of declining transparency on the other: Rowback on EU green rules.
And the FT is not alone in this assessment:
- The ECB warns that companies with >500 to <1,000 employees should remain within the scope of the CSRD. In addition, significant institutions (banks) should report regardless of their size. Reason: Without reliable data, key foundations for supervision, financial stability, monetary policy, and climate/nature-related measures are missing (3.1.7).
- Accountancy Europe also warns that limiting the scope to companies with >1,000 employees would massively thin out the data base – with consequences for capital allocation and risk assessment.
- The CSRD itself warns explicitly in paragraph 14: Without political action, the gap between users’ information needs and the data provided by companies will grow – resulting in potential systemic risks to financial stability.
Why we need a new term
Sustainability and ESG – both terms that were first hyped and then burned. This threatens to obscure their actual benefits. Climate change, technological change, raw material shortages, fragile supply chains, geopolitical crises – these megatrends have a direct impact on the stability and future viability of companies. This requires a more comprehensive assessment of risks, the targeted exploitation of opportunities, and the systematic involvement of stakeholders.
What does this mean for companies?
That’s why companies should talk much more about resilience – and about what data we need to be able to make an informed assessment of companies’ resilience before systemic risks shake the economy. A look at a frontrunner: NBIM (Norwegian Government Pension Fund) has long since taken action. For NBIM, reliable data is an absolute prerequisite for securing investments in the long term.
In recent months, we have discussed the concept of resilience with representatives from research, banks, insurance companies, businesses, and NGOs. One thing is clear: if we want to get back to basics, we need to take a broader approach. At cometis, we traditionally combine the lens of the capital market with that of sustainability consulting. Together, we are therefore working to operationalize the concept of resilience in such a way that companies can more clearly highlight its benefits and uses in the future, beyond the question of whether sustainability is a mandatory exercise or “part of their DNA.”
Über cometis
For 25 years, we have been combining capital market expertise with in-depth sustainability analysis and structured consulting approaches. In over 1,000 mandates, we have learned to be both a long-term partner and a flexible source of expertise. Whether it’s an IPO, an M&A transaction, a (double) materiality analysis, or the complex field of ESG regulation, we bring clarity to challenging issues and create a solid basis for decision-making. Our services are tailored to promote exactly what matters to you— whether it is economic success, sustainable impact, or, ideally, both.