The European Omnibus did not kill ESG: it transformed it from a mass legal obligation into a competitive market advantage. The demand for reliable ESG data is shifting from regulators to investors, banks, and buyers, and ESG ratings themselves are now under supervision.
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The new regime (Directive (EU) 2026/470, in force since 18/03/2026). CSRD: threshold >1,000 employees AND >€450M net turnover, ~80% of initially targeted companies are out of scope; listed SMEs excluded; non-EU: >€450M EU turnover (FY28). CSDDD: >5,000 employees AND >€1.5Bn, implementation delayed to 2029, sanctions capped at 3% of global turnover, no harmonized civil liability regime. Simplified ESRS: -60% to -70% of datapoints, adoption targeted for mid-2026, assurance standard postponed to 1 July 2027. Taxonomy: automatically aligned with the new CSRD scope. Counter-current: Regulation (EU) 2024/3005 on ESG rating agencies has been applicable since 2 July 2026, supervision of ratings; EUDR (deforestation) applicable from 30/12/2026 for large operators.
Market interpretation. Pressure goes private: value chains (large companies will continue to demand data from their suppliers via the voluntary VSME standard), finance (banks’ GAR, SFDR), and buyers. Scarcity is shifting: what is lacking is no longer the declaration, but continuous, comparable, and verifiable ESG data, including on-chain (tokenized carbon, ETACI index).
Allocation implications. Companies that maintain quality reporting despite being out of scope will retain a cost-of-capital advantage; monitor EU/US regulatory arbitrage. For asset managers: regulated ESG rating becomes an auditable input, integrate near-real-time compliance indices rather than annual reports.
POSITIVE on ESG data infrastructure (ratings, continuous measurement, quality carbon); the “end of ESG” is a misunderstanding of the political cycle, not a structural trend.
