The EU’s so-called Omnibus proposal has sent ripples through the sustainability field in recent months. For many companies, it means a postponement of reporting obligations – but does that also mean a pause in sustainability efforts? Not if you ask Stine Ferguson, Head of Sustainability at PwC Østfold.
– I believe it’s just as important to manage sustainability risk as any other business risk – whether financial, operational, or environmental. Companies must understand that now is not the time to put sustainability work on hold, says Ferguson.
PwC and the Role of an Advisor in the Green Shift
PwC (PricewaterhouseCoopers) is one of the world’s largest consulting firms, with over 364,000 employees globally across 151 countries – and more than 2,600 in Norway, spread across 27 offices. As an advisor at the intersection of strategy, sustainability, and regulatory compliance, Ferguson brings extensive experience from both public and private sectors. Her official title is Senior Manager and Head of Sustainability at PwC Østfold.
– I work on sustainability strategies, carbon accounting, the Norwegian Transparency Act, and collaborate closely with our audit teams on sustainability reporting assurance in line with the CSRD*, she explains, adding:
– I have experience with ESG* both as a student and as a sustainability manager, and have developed comprehensive sustainability strategies and implemented them across projects and organizations. I’ve also led projects to ensure clients meet regulatory requirements.*
Stine works closely with both internal teams and clients to integrate sustainability into business models and strategies – contributing to a more sustainable future.
What Does the Omnibus Proposal Actually Mean?
The Omnibus package is the EU’s attempt to simplify and harmonize sustainability reporting requirements, especially to make it easier for small and medium-sized enterprises to keep up with the green transition. The aim is to increase competitiveness, boost European industry, and close the gap with other global powers. It also seeks to strengthen innovation and reduce greenhouse gas emissions.
– The proposal primarily postpones several reporting requirements by two years for companies originally obligated to report for the year 2025, says Ferguson.
The threshold for mandatory reporting is also increased from 500 to 1,000 employees. Listed companies must still report as planned, with the first deadline in spring 2025.
Don’t Put Sustainability on Hold
Even though many companies now have more time, Ferguson strongly warns against pausing their efforts.
– Many businesses have already invested in data systems, hired staff, and initiated processes. Putting that on hold is not only bad for the climate – it’s bad for business, she says.
Ferguson points out that climate challenges and market expectations won’t disappear with the delay.
– Sustainability risk makes companies vulnerable. Even if regulatory requirements are postponed, the world still faces major climate and nature challenges, which will impact businesses financially and demand massive transformation and innovation.
– Companies that take this seriously will be better positioned in tenders, investments, and recruitment, she emphasizes.
New Requirements – and New Opportunities
While simplification is underway, Ferguson believes there’s still opportunity. The EU’s voluntary framework for SMEs – VSME* – has already been launched.
– It offers a simplified entry point to sustainability reporting. The EU has proposed that the voluntary standard eventually be implemented as a delegated act – and in Norway, it’s likely to become a formal regulation, she says.That means what is currently “voluntary” may soon become mandatory. Ferguson therefore recommends companies start now with key tools such as double materiality assessments and ensure their sustainability reporting is built on recognized frameworks.
Competitive Advantage – Not Just Compliance
Sustainability is no longer just about reputation – it’s business strategy. Ferguson highlights five key reasons why starting early pays off:
- Transparency: Establish strong stakeholder dialogue to share relevant information.
- Reputation: – Sustainable practices enhance a company’s image, keeping it relevant in a world where stakeholders demand responsibility and renewal.
- Innovation and Differentiation: – Use this opportunity to stand out – to investors, customers, and employees.
- Cost Savings: – For example, through energy efficiency and waste reduction.
- Tender Advantage: – Public and private clients increasingly demand documented sustainable solutions.
– Sustainability is no longer optional. It’s essential for any modern company aiming for long-term success, says Ferguson.
EPDs as a Strategic Tool
Ferguson also sees EPD (Environmental Product Declarations) as a central component in the green transition.
– EPDs provide a structured, comparable, and analytical approach to environmental impact – which will be crucial in the shift toward a circular economy, she says.
She highlights how EPDs offer greater insight into resource use and efficiency – and how companies actively working with Life Cycle Assessments (LCAs) can more easily document their environmental efforts and reduce emissions.
Carbon Accounting: A Minimum Standard for Best Practice
Even with the Omnibus delay, companies should continue – or begin – reporting and set targets for greenhouse gas reduction in both Scope 1 and Scope 2.
– While the delay makes this optional, I recommend companies report on Scope 3 emissions – especially those with complex supply chains. Scope 1 and 2 are relatively straightforward, but it’s within Scope 3 that the major emissions lie, Ferguson explains.She believes systematic work and accurate data collection are essential – and that methodologies like LCA (Life Cycle Assessment) and EPD tools will play a key role in this process.
Social Sustainability and a Holistic Approach
Much of the sustainability conversation centers around climate and environment, but Ferguson reminds us that the social dimension (the “S” in ESG) is just as critical.
– Health and safety, whistleblowing, due diligence assessments – these matter equally. Sustainability is about the whole picture, not just CO₂, she says.
Final Advice
Carbon accounting is a minimum standard for best practice: Know where you stand, show you take responsibility, and identify opportunities to cut emissions. Differentiate now – don’t wait, says Ferguson.
Regulatory demands are evolving rapidly, and reporting is shifting from storytelling to verifiable data. Companies that embrace sustainability now can stay ahead – both strategically and in terms of values.
– Starting early with sustainability can give companies a strategic edge in an increasingly competitive market – while contributing to a more sustainable future, she concludes.
FACTS:
CSRD (Corporate Sustainability Reporting Directive):
An EU directive that tightens sustainability reporting requirements.
Effective from 2023, it mandates more companies to report on sustainability alongside financial reporting.
Key points:
- Reports must follow common EU standards (ESRS)
- Must cover double materiality: both how the company impacts the environment/society and how sustainability affects the business
- Must be assured by an independent auditor
In short: CSRD makes sustainability measurable, comparable, and mandatory
ESG (Environmental, Social, Governance):
A framework for assessing how sustainable and responsible a business is.
- E (Environmental): Emissions, energy use, resource management
- S (Social): Human rights, labor conditions, equality
- G (Governance): Transparency, anti-corruption, ethics, leadership
ESG is key in investment decisions and sustainability reporting.
VSME:
Stands for Voluntary Standard for Micro and Small Enterprises, developed by the EU.
A simplified sustainability reporting framework designed for small businesses as an alternative to the more complex CSRD standards.
While voluntary, it’s proposed to become a formal regulation in Norway, making it de facto mandatory for many.
The Three Scopes of Emissions:
Scope 1: Direct emissions from operations (e.g., fuel use in vehicles or on-site combustion)
Scope 2: Indirect emissions from purchased energy (e.g., electricity, district heating)
Scope 3: Other indirect emissions – e.g., logistics, purchased goods/services, employee commuting, product use and end-of-life. Often the largest and most complex category.