The choices that we make: Sustainability reporting under Omnibus
Governance means choices. The choices that enable smooth advancement of a company through constantly changing environment. In November 2025 GUBERNA celebrated the companies that made their choice and were selected for the Belgian Awards for sustainability reporting.
A trial, as any innovation, sustainability reporting requires pioneering spirit and readiness to go an extra mile. As GUBERNA keeps repeating, sustainability reporting is not the goal, but the means to serve a different, wider goal: sustainable value creation. Since 2019, the Belgian Corporate Governance Code, or Code 2020, sets that goal as the one guiding business principles for the boards of directors of listed companies, and as a recommendation of any business endeavour in the country.
A shift towards sustainable value creation has emerged in a wider global setting. Starting from early 2000s we have witnessed a clear international trend for integrating environmental and social agenda into business reality, with soft law instruments pushing the agenda forward. Since 2020, Europe accelerated the movement taking up a frontrunning role. With the Green Deal, it wanted to create a new framework and thus new opportunities. It wanted to ensure that economic growth is environment-friendly and comes together with employees’ well-being.
However, EU-wide initiatives could be slow, while the world keeps changing. Europe has started looking for the ways to raise its competitiveness, and the search for red tape reduction started with a radical, 90%, reduction of sustainability reporting scope*.
This shift took away compliance component of sustainability reporting for the majority of companies, and at the same time it pushed forward the front-runners. Think about it. If reporting is done only in order to fulfil certain legal obligations, it remains a formal box-ticking exercise and thus could be treated as a red-tape or a compliance burden. If, on the contrary, we treat it as a business tool, we can explore and exploit new opportunities that it reveals.
What are those opportunities?
First, reporting helps in dealing with increasing risks. Technological disruptions, social unrest, geopolitical pressures – the nature of risks business is confronted with is changing; the number of such risks keeps growing; and they have to be proactively addressed.
Second, reporting serves in seizing emerging growth opportunities. Every change opens new markets. Currently, China leads global race for clean energy. Its clean energy investment was more than USD 625 billion in 2024, which is 30% of the global investment, which means 10% ahead of the EU (18%) and of the US (19%). Besides, China has launched its sustainability reporting trial**.
Besides, reporting helps in identifying existing dependencies and in shaping new opportunities behind them. In other words, it pushes us to go outside of the box of “business-as-usual” habits.
Finally, when sustainability becomes an integral part of corporate strategy, the reporting becomes an integral part of strategy setting as well.
Chinese investment in clean energy has almost doubled since 2015. While the presence of the Asian super power has mostly been felt in ASEAN countries before, now it is rapidly expanding also into Africa and Latin America.
Why? To seize the opportunities of inevitable transition to clean energy. As recent analysis made by LSE identifies, Chinese investors seek access either to host countries’ markets, or to third-country markets, or they want to secure access to raw material inputs.
BAS Award has brought together brilliant examples of effective mastering of sustainability reporting. 88 % of Belgian companies were already reporting on sustainability before Omnibus. That means that Belgian companies have managed to well integrate the original CSRD settings into their reporting procedures, see the results of KPMG study here. The companies invested a lot of resources in exploring the new tool, in reviewing their own work with a new angle, and in sharing their findings with a wide circle of stakeholders, thus expanding the use of reporting as a tool across Belgium, across Europe, across the world.
Belgian reports of the first wave demonstrate that companies took the exercise seriously, invested resources into it, and that paid back. One of the key lessons learnt on this way is that the reporting has helped to mobilise a company as a whole. This means that by deeply reviewing their existing business processes, possible vulnerabilities and possible openings, the companies re-invent their understanding of themselves and start a move towards re-shaping their business models.
Two important moments to conclude with:
First, reporting depends on the quality of input: if we invest into it, the body of data starts working for its users as well as for a wider community and up to the whole ecosystem. It works through setting benchmarks, through enabling effective comparisons, through shaping new business approaches and thus the future.
Second, reporting makes a part of strategic decision-making, supplying strategy with tools and data, crucial in the turbulent periods of high uncertainty like the one we are all going through now.