The firm held another session of the Pérez-Llorca/IE Chair entitled “The reform of the CSRD and CSDDD Directives: a new framework for sustainability reporting and corporate due diligence” at its Madrid office. The event examined the new legal framework following the publication of Directive 2026/470 in the Official Journal of the European Union on 26 February 2026.
The session was moderated by José María de Paz, ESG Criteria and Climate Change Regulation partner at Pérez-Llorca, and featured contributions from Ana Puente, Head of Sustainable and Digital Finance at the Ministry of Economy, Trade and Business; Santiago Durán, President of the Institute of Accounting and Auditing (ICAC); Juan Carlos Delrieu, Director of the ESG Office at the Bank of Spain; Marco Masip, Director of Sustainability Strategy and Reporting at Telefónica, and Sara Sánchez, Associate Professor and Head of the Private Law Department at IE Law School.
A new framework for regulatory simplification
During the session, the speakers examined how Directive 2026/470 narrows the scope of certain corporate sustainability obligations and introduces significant changes to the availability and quality of information. While opening the debate, moderator José María de Paz emphasised that:
“Sustainability data is not an end in itself; it is the essential raw material for assessing climate risks and complying with SFDR obligations. The reform drastically reduces the number of companies subject to the requirements, replaces ‘reasonable verification’ with ‘limited verification’, and abolishes harmonised civil action. The fundamental question is whether the resulting system will produce sufficient information to support the European legislator’s objectives.”
The impact on verification and civil liability
The round table discussion addressed the technical and legal implications of the reform. Santiago Durán, President of the ICAC, warned of the risks of revising a regulatory framework before it has been fully implemented and pointed out that the reduction in scope and the limitations on verification raise questions about the system’s ability to provide a true and fair view of sustainability information:
“We are witnessing a review of the regulatory framework prior to its full implementation. The reduced scope and limitations on verification raise questions about the system’s ability to provide an accurate and consistent picture of sustainability information.”
Sara Sánchez, Associate Professor and Head of the Private Law Department at IE Law School, went on to address the legal consequences of the reform on the corporate due diligence regime and emphasised that:
“With a view to simplification, the civil liability regime is undergoing a fundamental overhaul. The fragmentation of the applicable regulations may lead to greater complexity and legal uncertainty for businesses.”
Implications for the financial sector and corporate strategy
The narrowing of the regulatory scope, which could bring the number of companies required to report sustainability information down to between 300 and 600, has a direct impact on the regulator’s requirements and on companies’ internal management.
The participants also agreed that the succession of regulatory changes had created complexity before the initial framework could be fully implemented, a situation which creates uncertainty and hinders business planning.
In this context, Juan Carlos Delrieu, Director of the ESG Office at the Bank of Spain, warned of the implications that a reduction in the available information could have for financial supervision and risk management, noting that:
“Simplifying the disclosure of sustainability information should not be interpreted as deregulation. From a supervisory perspective, the aim is to improve efficiency and proportionality, not to lower prudential standards. However, the reduction in reporting by companies creates tension, as it limits the availability of data that banks need to identify, measure and manage risks, with potential implications for financial stability.”
Marco Masip, Director of Sustainability Strategy and Reporting at Telefónica, emphasised the need for reporting frameworks to address the real needs of different stakeholders and provide genuine value to organisations, stating that:
“The main frustration is producing information that isn’t useful. The challenge is not just how much is reported, but ensuring that the information meets the real needs of the people using it.”
The debate also highlighted the need to move towards reporting models that ensure the usefulness of the information, the proportionality of the obligations and legal certainty for the various stakeholders involved.
The role of public policy and economic transformation
Ana Puente, Head of Sustainable and Digital Finance at the Ministry of Economy, Trade and Business, focused on the value of public-private partnership when it comes to implementing the European framework for sustainable finance in Spain:
“Sustainable finance is a means of transforming the real economy in the face of climate risks, and of improving the competitive position of our companies. Although the Omnibus Directive has narrowed the scope of companies required to report on sustainability, there are incentives and levers that can encourage voluntary reporting where there is a clear return. This is the case with Eco-Track, which we have launched at the Sustainable Finance Council thanks to a public-private partnership. It’s a tool that enables SMEs to identify sustainability-related data points that are extremely useful to financial institutions in meeting supervisory expectations regarding the management of climate-related risks in their loan portfolios.”
The roundtable also addressed the role that voluntary reporting standards can play and the need to develop guidelines and incentives to facilitate the collection of useful, comparable and proportionate information for companies that will fall outside the new regulatory scope.
The Pérez-Llorca/IE Chair reaffirms its position as a leading forum for the development of robust legal strategies in response to regulatory developments in the European Union. Through this collaboration, the firm renews its commitment to supporting its clients in regulatory compliance, providing the technical expertise required to turn regulatory challenges into business opportunities.