Key takeaways
Last February, the European Commission presented the draft Omnibus Directive designed to simplify extra-financial regulations (CSRD, CS3D, Taxonomy), with proposals such as postponing the CSRD by 2 years and raising the eligibility thresholds. As a result, 80% of the companies initially concerned - including the majority of medium-sized companies and all SMEs - would no longer be subject to these obligations. These announcements have provoked contrasting reactions: some see them as a means of boosting competitiveness, while others denounce a weakening of the Green Deal's ecological ambitions.
These regulatory changes are also part of a wider context, marked by a growing questioning of climate policies. This context could spontaneously lead companies to revise their climate ambitions and adopt a wait-and-see attitude: our climate experts present here the major advantages for maintaining and strengthening your action in the fight against climate change, by accelerating your decarbonisation strategy.
8 good reasons to accelerate your climate strategy
1. The Volontary Sustainability Reporting Standard for non listed SMEs (VSME) is not an empty shell
Published in December 2024 by EFRAG, the initial aim of this standard is to help micro, small and medium-sized enterprises (SMEs) and very small companies (VSEs) to meet the demands of major clients subject to the CSRD, without having to bear the entire burden of reporting. Based on the same approach as the CSRD's ESRS, it differs in that it is voluntary and streamlined. Its reporting framework is nonetheless fairly comprehensive: on the environmental side, for example, it recommends the publication of greenhouse gas emissions across the 3 scopes (ESRS E1), and requests information on water, air and soil pollution (ESRS E2), water and marine resources (ESRS E3), biodiversity (ESRS E4) and the circular economy (ESRS E5).
In addition to promoting transparency vis-à-vis stakeholders, the benefits of the VSME for companies are far from negligible. According to the cost-benefit report published by EFRAG in December 2024, the results are clear:
- On average, a 20% increase in sales to large groups (most of which remain subject to the CSRD);
- An estimated net benefit of €2.6 billion in 2028 for European SMEs. This increase can be explained by several factors, including a reduction in operational risks that are not systematically identified in financial reports, and lower costs (particularly borrowing costs).
2. Reallocate resources earmarked for the production of the sustainability report to actions with an impact
The aim of the European Commission's Omnibus project is to ‘reduce administrative and regulatory burdens while maintaining the objectives of ecological transition’. This ‘simplification shock’ aims to free up financial and human resources for businesses, with estimated savings of nearly €6 billion.
Over and above the direct financial savings (i.e.: verification missions by the Sustainability Auditor, external consultants, reporting tools, etc.), streamlining the sustainability report will free up resources and redirect them towards climate-friendly action, such as investment in more environmentally-friendly mobility for employees or the renovation of buildings. According to a C3D survey, compliance with the CSRD generates an average additional workload of 1 to 2 ‘Full Time Equivalents’ (FTEs).
It is also important to stress that the lifting of regulatory obligations does not erase the climate challenges that companies (and society) will have to face. This is therefore a good opportunity to reiterate, with the very apt slogan of the Association pour la Transition Bas Carbone (ABC), that the meaning of any climate initiative goes beyond reporting: ‘Count to know, know to act, act to reduce’.
3. Benefit from proven methodologies and tools to help you structure your climate strategy
For SMEs and SMIs, which often have limited resources when it comes to CSR, it's not always easy to know where to start when it comes to implementing a climate strategy. In addition to the Climate Fresco, which has established itself as an effective basic tool for raising employee awareness of environmental issues, there are several relevant guidelines that can help companies structure a climate strategy and concrete actions tailored to their maturity and challenges:
- The Bilan Carbone® method, created in 2004 at the initiative of ADEME, has been enriched over the years, with a 9ᵉ version implemented in 2025. Much more than a simple carbon accounting benchmark, this methodology aims to ‘offer a complete and coherent low-carbon transition approach’, in particular by integrating a transition plan at the heart of its methodology. A key advance in this version is the introduction of several levels of maturity (Initial, Standard and Advanced), enabling companies to progress through the process at their own pace.
- The Diag Décarbon'Action: launched in 2021 by Bpifrance in collaboration with the Association Bilan Carbone (ABC), is aimed at SMEs and medium-sized companies. This support involves a greenhouse gas (GHG) emissions assessment, followed by a customised action plan. A highly effective way of initiating a climate change initiative, it also has the advantage of being subsidised by ADEME to the tune of €4,000 excluding VAT. It is proving an undeniable success, with more than 2,000 companies receiving support by 2024.
- ACT pas-à-pas : launched in 2015 by ADEME and the Carbon Disclosure Project (CDP), this initiative aims to build a robust climate strategy, incorporating a low-carbon transition plan. This methodology is distinguished by its approach, which places climate issues at the heart of the company’s strategy, through an analysis of climate-related risks and opportunities, as well as a forward-looking exercise that questions the future of the business model in a low-carbon world in the short, medium, and long term. As the most comprehensive methodology, ACT Pas-à-Pas also enables companies to meet the majority of reporting requirements under the CSRD and the VSME.
4. Reduce your costs and boost your competitiveness
Aligning the interests of decarbonizing companies with their profitability is at the heart of the dynamics of environmental transition. The European Union has clearly understood this by making decarbonization one of the three main lines of action of the ‘Competitiveness Compass’ presented in January 2025. This bears witness to the strategic dimension of decarbonization, which year after year is becoming an increasingly central component of business performance.
A study conducted by BCG in 2025 is particularly encouraging: 25% of companies report a significant improvement in their profitability (+7%). These gains are made possible by lower operating costs resulting from the optimization of industrial processes, reduced energy consumption and increased use of renewable energies. As well as being more competitive, these companies are more resilient because they are less exposed to the volatility of fossil fuel prices.
More generally, it is important to emphasize that the return on investment (ROI) of decarbonization actions depends on several parameters:
- The nature of the actions implemented (sobriety, efficiency, energy or material substitution, etc.);
- The maturity of decarbonization technologies;
- The business sector.
To build a robust and effective decarbonization strategy, ROI is a key indicator which, when crossed with the potential for reducing emissions, makes it possible to prioritize the actions to be deployed and to anticipate the associated CAPEX and OPEX. Once the “quick wins” have been implemented, companies can concentrate their resources on more transformative actions, such as product eco-design (taking environmental issues into account from the design phase of a good or service, in order to minimize its impact throughout its life cycle - in particular by focusing on materials, durability, reparability or end-of-life), or low-carbon sourcing (giving preference to suppliers, raw materials or modes of transport that generate fewer greenhouse gas emissions, for example by relocating part of purchases or selecting recycled inputs or inputs from sustainable sources)... Although they require more substantial initial investment, these levers offer considerable potential for decarbonization and are accompanied by strategic opportunities.
However, when it comes to business models that are truly sustainable and compatible with respect for planetary limits, their profitability has yet to be largely invented. Pioneering companies can, however, capitalize on the indirect benefits of decarbonization, in particular the attractiveness and retention of talent, as well as a more resilient value chain that is less exposed to environmental risks.
5. Boost your attractiveness
The CCI's 2024 ‘Baromètre des entreprises françaises’ reveals that ‘maintaining or developing employee commitment’ is the main HR challenge. Combined with the results of the Beeshake and Act for Now study, which highlights employees' expectations of their company's CSR commitments, a reinforced decarbonisation strategy would improve the company's attractiveness.
Involving employees in this approach strengthens their feeling of being part of the transition, while offering the opportunity to review the company's governance and increase their decision-making power. A Harris Interactive study illustrates this clearly: 65% of 18-30 year-olds said they would be prepared to give up applying for a job in a company that did not take sufficient account of environmental issues.
6. Get closer to your suppliers and strengthen links with your value chain
The importance of a robust value chain for a fluid and sustainable business is well established. The shortage of materials in 2023, the rise in raw material prices linked to geopolitical uncertainties and the Covid-19 pandemic have been - and still are - strong reminders of the risk of companies becoming dependent on their suppliers.
From the point of view of climate strategy, given that the ‘Purchasing’ emissions item very often accounts for the majority of companies' CO2 emissions, a genuine commitment on the part of their suppliers is essential. It enables many levers to be activated to reduce CO2 emissions, which are often beyond the scope of direct action by companies. This also highlights the issue of the influence that smaller companies (SMEs or medium-sized companies) can have on a principal: without active collaboration, it may be difficult for the latter to achieve its decarbonisation objectives.
A good example of this dynamic is the Danone group and the SCARA cooperative. Together, they have set up a mutual commitment to prevent environmental requirements penalising SMEs without compensation. Danone is committed to better remuneration for farmers and long-term contracts, as well as funding for certain tools needed to work in a more environmentally virtuous way. The approach is collaborative: the challenge for SCARA is to agree on the vision and share the purpose of environmental and social projects between suppliers and principals. In this way, the Group is improving its own environmental performance across its value chain, while working with its suppliers to improve theirs.
7. Secure your markets and gain access to new ones
As almost 60% of French SMEs are integrated into the value chains of large companies, they have a direct stake in improving their climate commitments. In its 2023 report, the Net Zero Tracker research consortium estimates that nearly 60% of the world's major companies have adopted carbon neutrality targets.
The purchase of goods and services is the main source of GHG emissions for the majority of companies, as mentioned above. It is therefore crucial to involve suppliers in the decarbonization strategy in order to meet the targets, by including environmental clauses in calls for tender, assessing the CSR maturity of suppliers and subcontractors (questionnaires, audits, etc.), environmental certifications or even more specific requirements, such as carrying out a carbon audit or implementing a decarbonization plan.
While the effective implementation of these clauses varies from one contracting authority to another, an increasing number of stakeholders now place significant emphasis on environmental criteria when selecting their suppliers. For mid-sized companies and SMEs, failing to implement an ambitious decarbonization strategy poses a risk—not only of penalties but also of being excluded from certain markets.
In terms of public procurement—which represents the primary source of revenue for nearly 30% of French SMEs and mid-sized companies—the inclusion of an environmental criterion in tenders will become mandatory as of 2026. If your business is concerned by this shift, the time to act is now: anticipate the change and turn your climate strategy into a competitive advantage for your business!
8. Reclaiming Long-Term Thinking and Ensuring Business Resilience
The consequences of climate change are already tangible, as highlighted in a recent BCG study (“Climate Inaction: The Risk of a 22% Drop in Global GDP by 2100”):
- Climate-related damages amounted to $1 trillion between 2020 and 2024;
- Transition risks are increasingly evident and closely monitored by organizations that recognize these impacts will only intensify over time—potentially leading to a 22% loss in global GDP by 2100.
In this context, it is crucial for companies to develop a climate strategy based on double materiality: considering not only the impact of their activities on the environment, but also how climate change affects their operations. Despite a natural tendency among organizations and individuals to focus on short-term results, committing to long-term thinking will be key to business sustainability.
Anticipating longer-term disruptions and investing in a liveable future helps prevent the “tragedy of the horizon”: the paradox where financial systems acknowledge long-term risks and the need to prepare for them, yet continue to prioritize short-term gains.
Businesses that can identify vulnerabilities across their value chains—and integrate those insights into long-term strategic decisions through adaptation and mitigation mechanisms—will be better equipped to ensure their resilience in an increasingly uncertain and volatile environment. This is where existing methodological frameworks, as previously mentioned, become essential tools for driving a successful and sustainable transition.
It is essential for companies to maintain their climate ambitions, despite recent regulatory rollbacks.
At RSM, our experts support organizations in designing and implementing robust and forward-looking climate strategies—empowering them to remain competitive and resilient over the long term.
- OMNIBUS: Commission Simplifies Rules on Sustainability and EU Investments, Delivering Over €6 Billion in Administrative Relief - European Commission
- WMO Confirms 2024 is the Hottest Year on Record, with Temperatures Approximately 1.55°C Above Pre-Industrial Levels – World Meteorological Organization
- €300 Billion in Losses Due to Climate Disasters in 2024 - Novethic, December 11, 2024
- ESG Compliance: A Transformation Opportunity - L'info Durable - 28/02/2025
- CSRD: After Omnibus, Uncertainty Among Companies and CSR Stakeholders - Novethic - March 6, 2025
- Guide for Analyzing Corporate Performance in Carbon Transition – Institute for Sustainable Finance - Institut de la Finance durable - November 2024
- First Months of CSRD Implementation: Insights from the 85 Companies Surveyed by the C3D - C3D - June 27, 2024
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