ESG: Between Obligation, Voluntary Action, and Strategy
The year 2025 marks a turning point in the landscape of ESG reporting. With the so-called "Omnibus Package" in March 2025, the EU adopted far-reaching amendments to the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS). Small and medium-sized enterprises are particularly affected: Many of them are now formally exempt from reporting requirements. But what does that mean in practice? And how does a company navigate—amid regulatory pressure, stakeholder expectations, and competitive advantages—through the jungle of ESRS, GRI, IFRS S1/S2, TNFD, CDP, EcoVadis, S&P Global CSA, and B Corp?
This article provides a structured overview, highlights the differences between statutory, voluntary, and valuation-based standards—and offers sound recommendations for action, particularly for German small and medium-sized enterprises.
Classification: Differences Between Legal Obligations, Voluntary Frameworks, and ESG Ratings
Within the ESG universe, three groups can be distinguished:
- Mandatory standards: Specifically, the ESRS, which are part of the CSRD. They apply to large companies and capital market-oriented SMEs in the EU—currently to companies with more than 250 employees, and soon possibly only to those with 1,000 or more employees (Omnibus).
- Voluntary frameworks: such as GRI, IFRS S1/S2, or TNFD. They promote standardization, offer global compatibility, and help companies disclose ESG-related issues in a structured manner even in the absence of a legal obligation.
- Assessment systems & ratings: CDP, EcoVadis, S&P Global CSA, and B Corp measure ESG performance based on standardized questionnaires and comparative metrics—which is particularly important for customers, investors, and business partners.
An Overview of the Most Important Standards and Frameworks (including 2025 Updates)
| Standard/initiative |
Mandatory / Voluntary / Rating |
Reporting frequency |
Relevant stakeholder groups |
| ESRS | Requirement (CSRD) | Annually | European Commission, investors, customers |
| VSME | Voluntary | Annually | Customers, banks, suppliers |
| IFRS 1/2 | Voluntary / Market-driven | Annually | Investors, Capital Markets |
| TCFD | Voluntary (replaced) | One-time / Annual | Investors, banks |
| GRI | Voluntary | Annually | Stakeholders, NGOs, the public |
| DNK | Voluntary | Annually | Public sector, local governments |
| TNFD | Voluntary | Annually | Investors, environmental organizations |
| CDP | Rating (Based on requests) | Annually | Investors, customers |
| EcoVadis | Rating (Customer Demand) | 2 months after the request | Customers, purchasing departments |
| B Corp | Certification | Every 3 years | Employees, customers, investors |
| S&P Global CSA | Rating | 2-month windows | Credit rating agencies, investors |
Deep Dive: Implications for German SMEs
For small and medium-sized businesses, 2025 will bring new opportunities—but also new challenges:
- Formal exemption under the Omnibus Package: Companies with fewer than 1,000 employees are often no longer subject to the CSRD.
- Factual requirements are increasing: Major clients (e.g., OEMs), banks, and insurance companies continue to demand structured ESG data—often based on ESRS or VSME.
- Competitive and reputational pressures are mounting: Companies that cannot provide ESG information risk losing contracts or financing opportunities.
Recommendation: SMEs should use VSME as a foundation, combined with GRI elements for voluntary transparency or with CDP/EcoVadis to meet customer requirements. A DNK declaration may also be useful—especially for municipal or public contracts.
Recommendations: How Companies Choose the Right Strategy
Choosing the right frame depends on three factors:
- Regulatory implications: Is the company subject to reporting requirements? If so, there is no way around the ESRS.
- Stakeholder expectations: customers, investors, banks? Check which standards or ratings are required.
- Resources & Vision: How much internal expertise and budget are available? What sustainability goals does the company itself pursue?
Common scenarios & recommendations:
- Reportable companies (>1,000 employees): Full implementation of ESRS, supplemented by IFRS S2 to ensure international capital market eligibility.
- Non-compliant companies with large B2B customers: VSME + EcoVadis or CDP rating for supply chain transparency.
- Organizations with a public interest: DNK + GRI on voluntary disclosure and project participation.
- Impact-driven companies: B Corp certification to establish their position with customers, talent, and partners.
Conclusion: Strategic ESG reporting is becoming the norm
ESG reporting requirements are becoming more nuanced—but no less relevant. The fact that many SMEs are exempt from CSRD requirements does not give them a free pass to do nothing. On the contrary: companies that understand their stakeholders and anticipate their needs gain a genuine competitive advantage. By 2025, voluntary ESG reporting will be an integral part of strategic corporate development.
Interested in discussing ESG strategies? We’ll help you find the right approach—tailored to your stakeholders, your industry, and your resources. Contact us for a no-obligation initial consultation.