Companies’ environmental obligations, however, remain. Who will manage them? 

 

Why simplifying ESG reporting does not mean that environmental obligations are being relaxed and what requirements companies still need to address

How to coordinate obligations relating to CBAM, PPWR, emissions data and business partner requirements across different departments

When it makes sense for a company to have its own ESG specialist and how external support can ensure the ongoing management of its environmental agenda

 

Simplifying ESG reporting gives some companies administrative relief. Environmental requirements for businesses, however, have not disappeared. On the contrary, for many companies they represent an increasingly complex agenda that affects purchasing, production, logistics and business relationships. How can it be managed effectively when the range of obligations does not justify creating a dedicated in-house position?

Less reporting does not mean fewer obligations

European sustainability regulation is undergoing significant changes. Amendments to the rules for mandatory ESG reporting under the CSRD are reducing the number of companies subject to extensive reporting obligations. This does not mean, however, that environmental issues are no longer relevant to other businesses.

Alongside reporting requirements, there are many specific environmental regulations relating to products, materials, imports or the management of resources. Companies must address, for example, the Carbon Border Adjustment Mechanism (CBAM), new rules on packaging and packaging waste (PPWR), or requirements concerning batteries and other products. The scope of each obligation depends on the company’s specific activities.

Business partners also continue to request environmental data. Large customers may ask their suppliers for information on emissions, resource consumption or responsible supply chain management. Sustainability assessments through platforms such as EcoVadis are also an important issue for some companies.

Alongside legislative and commercial requirements, technical methodologies used by companies to assess their environmental impacts are also evolving. One example is the ongoing revision of the GHG Protocol, the international standard for calculating and reporting greenhouse gas emissions. The proposed changes may affect future requirements for emissions data, calculation methodologies and the way results are reported. Companies therefore need to monitor not only legislative developments, but also the technical standards they use to assess their environmental performance or provide information to business partners.

Environmental requirements also affect how companies present their products and services. A current example is Lufthansa Group, which renamed its Green Fare offering Impact Fare in autumn 2026. The company explains the change by reference to new regulatory requirements for environmental communications. The case shows that environmental compliance may concern not only production processes or reported data, but also commercial and marketing decisions. Companies therefore need to ensure that their environmental claims reflect actual impacts and are supported by relevant information.

A company may therefore be outside the scope of mandatory ESG reporting and still face significant environmental requirements that affect its costs, processes and business relationships.

Who is responsible for the environmental agenda within the company?

One of the greatest practical challenges is not only understanding the individual regulations, but also coordinating them across the company.

In a manufacturing business, the purchasing department may obtain information from suppliers, logistics may handle import obligations, production may deal with requirements concerning materials and packaging, and the sales department may respond to customer questionnaires. Finance then considers the implications for costs or investment decisions.

Individual departments may therefore deal with separate tasks without anyone having an overall view of the company’s environmental obligations, the related deadlines and how they interconnect.

This may lead to duplicated work, unclear responsibilities or situations where the company starts addressing a specific obligation only when the deadline for meeting it is approaching.

Environmental compliance is not a one-off task. Legislation evolves, customer requirements change and much of the data needs regular updating. In addition to expert assessment of individual topics, companies therefore need a system for managing them on an ongoing basis.

In-house specialist or external support?

For large companies with extensive environmental agendas, an in-house team of specialists may be the natural solution. The position is often different for medium-sized businesses.

Environmental requirements can be technically demanding, but their scope may not justify a full-time role. They also often span diverse areas requiring a combination of knowledge of environmental legislation, data handling, supplier processes and reporting. Creating a single in-house position therefore does not automatically mean that the company will acquire all the expertise it needs.

The decision is therefore not merely a comparison of the cost of an in-house employee and an external service, but also an assessment of the company’s actual need for specialist capacity throughout the year. Some obligations require regular coordination, while others require more intensive specialist involvement only at certain times.

One alternative is to outsource coordination of the environmental agenda. This model makes it possible to adjust the level of ongoing expert support to the company’s current needs and involve additional specialists as required, without the company having to maintain all the relevant expertise in-house over the long term.

The purpose of such cooperation is not only to respond to individual requirements, but above all to provide an overview of obligations, assign responsibilities and plan the necessary steps sufficiently in advance. A clear definition of the scope of cooperation and the division of responsibilities between the company and the external partner are essential for an effective external model.

From individual projects to ongoing management

The practical form of external cooperation can be illustrated by experience supporting companies that deal with several different environmental topics over the course of a year.

One example is the CBAM agenda, which entered its definitive phase in 2026. For affected importers, this means not only obtaining the relevant authorisation, but also continuously collecting data on imported goods and their emissions and preparing for related financial obligations. The first annual declaration for 2026 and the submission of the corresponding certificates fall due in 2027. Support for a company may therefore include several related activities, from assessing obligations and communicating with foreign suppliers to calculations and cost planning. The way these activities are connected shows why ongoing coordination, rather than a one-off expert assessment, is important.

The same company may also need to prepare documentation for an EcoVadis assessment, check the availability of environmental data or establish internal processes for collecting it regularly.

Although these are different topics, in practice they often involve the same departments, data sources and responsible individuals.

Experience providing ongoing client support shows that the added value lies not only in resolving an individual technical task, but also in linking related requirements and coordinating them over time.

BDO’s outsourced ESG manager service is based on this principle and is offered to companies seeking a flexible model of expert support.

Depending on the client’s needs, the cooperation may include monitoring relevant legislative changes, identifying obligations and deadlines, coordinating supporting documents and responsibilities, or providing methodological support when communicating with suppliers and business partners.

More extensive technical tasks, such as specialist calculations, assessing specific regulatory requirements or implementing new processes, may be handled separately according to their scope and complexity.

The ability to use data matters more than the amount of data

The environmental agenda is gradually becoming part of the ordinary management of business risks, costs and commercial relationships. For management, the decisive question is therefore not only whether the company can prepare a required report or respond to a customer questionnaire.

It is equally important to know which obligations apply to the company, who is responsible for them, what data is needed and what the financial or operational consequences may be.

Not every company needs its own ESG department. However, every company significantly affected by environmental requirements should have an appropriate way of managing them.

An outsourced ESG manager therefore need not be merely an alternative to an in-house specialist. It can be a way to combine expert knowledge, ongoing coordination and the practical needs of the business.

What environmental support does your company need?

Are you dealing with CBAM requirements, environmental data for customers, EcoVadis assessments, packaging legislation or other obligations? Do you need a one-off expert consultation, help with a specific project or ongoing support in managing the environmental agenda?

Use our contact form to let us know which topics you are currently dealing with and where you need help.

Based on your needs, we will jointly assess the appropriate scope of cooperation, from resolving individual technical issues to longer-term external support.