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Pérez-Llorca and IE Law School analyse the impact of Directive 2026/470 on corporate sustainability obligations

andrea.araujo — Tue, 30 Jun 2026 09:39:19 +0000

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.

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Omnibus I Legislative Package – The CSRD and CSDDD

Teresa Metello — Wed, 04 Mar 2026 10:13:37 +0000

On 26 February 2026, the final text of the Omnibus I legislative package was published,1 amending both the Corporate Sustainability Reporting Directive (“CSRD”) and the Corporate Sustainability Due Diligence Directive (“CSDDD”).

The package marks the culmination of a cycle of reforms launched in 2024 and follows the interim “Stop-the-Clock” and “Quick Fix” measures adopted in 2025. It forms part of the European Commission’s broader effort to recalibrate the EU sustainability framework in light of growing concerns regarding regulatory complexity, competitiveness, and proportionality.

You can read the full Legal Briefing here.

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The Pérez-Llorca/Universidad Carlos III European Centre for Digital Regulation analyses the role of data on sustainability

Pérez-Llorca — Tue, 20 May 2025 08:46:53 +0000

The Centre operates as part of the European Chair for Digital Regulation, an initiative co-directed by Pérez-Llorca and the Universidad Carlos III de Madrid

Pérez-Llorca and Universidad Carlos III de Madrid held a new session of the Pérez-Llorca/Universidad Carlos III European Centre for Digital Regulation which addressed the challenges and opportunities associated with the use of data in the field of sustainability.

Raúl Rubio, Intellectual Property and Technology partner at Pérez-Llorca, and David Ramos, Professor of Commercial Law at the Universidad Carlos III, opened the session by highlighting the Centre’s goal as a project aimed at generating technical and legal knowledge and promoting dialogue between the private sector, academia and public institutions, in order to address the regulatory challenges of the digital environment and contribute to the creation of more effective and sustainable regulations. Rubio stressed the importance of creating communities and forums for discussion with a multidisciplinary vision, and noted that “in an era of uncertainty such as the one we are living in, adequate regulation can provide greater certainty and guarantee transparency.” Ramos said that “when we talk about sustainability and long-term value creation, we’re talking about information, information that allows us to be more efficient, more productive and reduce risks.”

Sophie Marie Rathmes, Policy Officer in Sustainable Finance at the European Commission, then addressed the main challenges around sustainability data services from an institutional perspective. Rathmes stressed that high-quality, standardised and reliable data is essential for creating value opportunities and mitigating risks. In this regard, she gave a very interesting insight into the role of rules such as the Taxonomy Regulation, the CSRD Directive, and the Green Bond Regulation, how they interconnect, and, above all, how they contribute to creating a data ecosystem, connecting sustainable finance initiatives with digitisation and access to data initiatives. She then highlighted the Omnibus Regulation as a tool to reduce the administrative burden and simplify access to these platforms, while remaining committed to sustainability, offering very insightful thoughts on the regulatory proposals and the legislative approach. “Europe must continue to be a benchmark for regulatory innovation and sustainability,” she concluded.

This was followed by a panel discussion on the life cycle of sustainability data and the ecosystem of actors involved in its management, moderated by Raúl Rubio and featuring Itziar Castelló Molina, Reader in Sustainability and Digital Economy at Bayes Business School; José María de Paz, ESG Criteria and Climate Change Regulation partner at Pérez-Llorca; Sara Rodríguez, Global Head of Corporate Sustainability at Abertis; and the aforementioned Sophie Marie Rathmes.

Sara Rodriguez began her speech by addressing the central role of data in the internal transformation of companies and underlined its dual role: responding to external demands and guiding operational improvement. “Anything that is not measured cannot be improved,” said Rodríguez, who focused on the importance of building a common language within organisations and involving all professionals in this process, especially when objectives such as decarbonisation are linked to remuneration systems. She provided concrete examples of where this work is taking place, where there are challenges, and offered a critical perspective on the regulatory framework, which covers many “items”, but can make it difficult to build the company’s “narrative”.

Itziar Castelló reinforced this point by placing it in the broader context of a crisis of legitimacy surrounding sustainability. She noted that this legitimacy has been undermined by political factors and the spread of misleading narratives. For the past five years, the dominant discourse around ESG has promoted the idea that financial markets would lead the transition toward sustainability. This belief was reinforced by claims that ESG investments offered higher returns. However, about a year ago, enthusiasm within the financial sector began to wane. Castelló highlighted the critical role of regulatory bodies in restoring credibility to net-zero targets. This process of re-legitimisation, she argued, must be underpinned by reliable data and robust assurance mechanisms. “We must foster a narrative of accountability at all levels, based on processes of legitimisation and credibility,” she said.

From a legal perspective, José María de Paz brought up the need to redefine companies’ approach to non-financial reporting. He stressed the importance of integrating sustainability into corporate strategy and governance, noting that “it is not just about reporting, but about making better decisions, with the Board of Directors as a central actor in the process.” He also called for greater regulatory flexibility for companies to design their own processes without disengaging from common goals, and the importance of being able to build a narrative, but a true narrative.

Rathmes ended the first panel by stressing that many companies face difficulties in implementing the current requirements. She stated that the Omnibus Regulation seeks to simplify these processes without sacrificing climate ambition. “Our aim is to create a collaborative space that facilitates a sustainable transition and avoids regulatory uncertainty,” she concluded.

David Ramos gave way to a second panel focused on the roles and functions of the actors in the sustainability reporting ecosystem, with the participation of Edgar Löw, professor of Accounting Practice at the Frankfurt School of Finance & Management; Natalia Valls, head of Strategic Sustainability Reporting at CaixaBank; Nejc Smole, representative of the European Central Bank; and Nicholas Dodd, expert in climate finance and energy transition at RMI.

Natalia Valls noted the difficulty of complying with the disclosure requirements for ESG standards and rating agencies, providing noteworthy examples, and pointing out the need for standardisation and bridging the gap between voluntary and regulated measures. “Standardisation is key, but there are still significant gaps that hamper the comparability of information,” she stated.

Nejc Smole explained the approach of the European Central Bank, which has already integrated climate risk into its supervisory framework. He stressed that data must be complete, reliable and contextualised, warning that “quality is more important than quantity: understanding the context behind the data is essential for effective banking supervision,” while sharing some very interesting examples in the field of mortgage lending and energy performance certificates.

Nicholas Dodd explained the challenges in applying the PACTA methodology for climate risk and transition assessment, and advocated the use of forward-looking metrics to anticipate risks and target investments towards climate goals. “Energy transformation is not only achieved with commitments, but with informed decisions based on reliable, open and verifiable data,” he said. He also suggested that sustainability requires new, forward-looking metrics; data should not be a barrier, but a bridge to effective and measurable climate action.

Edgar Löw concluded the second panel by discussing the role of the auditor in the face of the growing demand for sustainability information from the financial sector, and gave examples based on his experience of the difficulties faced by auditors, especially in sustainability reporting. He emphasised the importance of ensuring data quality without creating excessive burdens. “Auditors must ensure quality without imposing unnecessary burdens in a still immature and complex environment,” he concluded.

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Highlights of the Sustainability Omnibus Package

Pérez-Llorca — Mon, 17 Mar 2025 07:48:27 +0000

On 26 February 2025, the European Commission published the first of a series of packages of legislative proposals known as “Omnibus I”. This package includes two proposals which seek to recalibrate the EU’s corporate sustainability obligations: (i) COM(2025) 80 final and (ii) COM(2025) 81 final. The most significant of these proposals, COM(2025) 81 final, seeks to amend three core instruments of the EU’s sustainability framework:

the “Audit Directive” (Directive 2006/43/EC);
the “Accounting Directive” (Directive 2013/34/EU), as amended by the Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464 or the “CSRD”); and
iii) the “Corporate Sustainability Due Diligence Directive” (Directive (EU) 2024/1760 or the “CSDDD”).