According to a survey conducted by Arendt and the House of Sustainability of the Chamber of Commerce, based on responses from 55 organisations with an operational presence in Luxembourg, companies are continuing CSRD preparation and reporting despite Omnibus I changes, while identifying “value chain data collection” as the main operational obstacle due to limits in supplier transparency and data reliability. Photo: Shutterstock

According to a survey conducted by Arendt and the House of Sustainability of the Chamber of Commerce, based on responses from 55 organisations with an operational presence in Luxembourg, companies are continuing CSRD preparation and reporting despite Omnibus I changes, while identifying “value chain data collection” as the main operational obstacle due to limits in supplier transparency and data reliability.  Photo: Shutterstock

Sustainability reporting under the EU’s Corporate Sustainability Reporting Directive is advancing in Luxembourg, but practical obstacles remain. A survey by Arendt and the House of Sustainability of the Chamber of Commerce, on Tuesday 27 January, shows that value chain data collection, rather than regulation, now poses the main challenge for companies preparing to report.

Sustainability reporting under the EU’s Corporate Sustainability Reporting Directive (CSRD) is increasingly shaped by information companies do not own, from supplier disclosures to emissions data across value chains. As explained by a survey dated Tuesday 27 January and conducted by Arendt and the House of Sustainability of the Chamber of Commerce, Luxembourg organisations identify value chain data collection as the main operational obstacle in CSRD preparation, even as many continue reporting despite changing scope and timelines.

The survey gathered 55 responses from organisations with a significant operational presence in Luxembourg. It primarily targeted corporate respondents and ESG/sustainability professionals at management level, covering CSRD preparedness, governance, double materiality, implementation challenges and resourcing, and benchmarking results against EFRAG, ESMA and CSSF analyses.

Reporting continues, even where it is voluntary

49% of respondents report on a voluntary basis, while 4% say they will not issue a sustainability report. 51% intend to report using the European Sustainability Reporting Standards, compared with 18% citing VSME and 8% citing GRI.

This reporting activity continues despite regulatory adjustments introduced through the Omnibus I package. 59% view Omnibus I positively and 41% feel neutral, with 53% saying it has not affected their sustainability reporting progress.

Omnibus I brings time, not operational simplicity

Respondents report that Omnibus I clarified reporting options and possible exemptions (29%), simplified taxonomy analysis (29%) and simplified the data collection exercise (23%). They also report that it did not simplify scoping and/or value chain analysis (65%), alignment with other regulations (65%) or assurance readiness assessments (59%).

Value chain data is the main bottleneck

The survey identifies “value chain data collection” as the biggest hurdle and lists recurring issues including “data reliability”, “limited supplier transparency”, “taxonomy interpretation” and “fragmented international standards”.

Respondents report being able to manage scoping, stakeholder mapping, greenhouse gas calculations and interactions with other regulations, but cite persistent difficulty with “complex data-collection requirements”, “uncertainty around Taxonomy alignment”, and integrating ESG risks and controls into financial reporting structures. At value chain level, “data collection, supplier transparency and emission tracking” remain the most difficult areas.

CSRD framed as more than compliance

The report states that “CSRD is increasingly approached as a strategic exercise, not only a compliance requirement”. In the results, 76% describe CSRD as a mix of compliance and strategic opportunity, while 12% view it purely as strategic.

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