Sustainability reporting in 2026: requirements, changes and practical implementation
For many companies, sustainability reporting in 2026 means not only new reporting requirements, but above all clearer processes, defined responsibilities and reliable data flows. This guide explains who is affected, what changes are planned, how to set up a robust reporting system and what mistakes you should avoid.
Sustainability reporting in 2026 sets out the requirements for companies to systematically collect, assess and publish sustainability information. This includes environmental indicators (such as greenhouse gas emissions under Scopes 1, 2 and 3), social aspects, governance issues, as well as other specific guidelines such as packaging or battery reporting. The aim is to ensure transparency for stakeholders, regulatory compliance and the improvement of corporate resilience.
The mandatory phases are primarily aimed at large companies; other companies may join on a voluntary basis or adopt the measures gradually. Specifically:
- Large capital market-oriented and non-capital market-oriented companies with more than 1,000 employees and a turnover in excess of €450 million are the focus of the first phases.
- However, medium-sized groups with several subsidiaries should take a proactive approach, as group structures make data sources and interfaces complex.
- Smaller companies are often only indirectly affected (e.g. as suppliers receiving reporting requests), but should nevertheless take steps to prepare for supply chain requirements.
A key factor in planning is which requirements will ultimately be incorporated into local law and from which financial year they will apply. In brief:
- There are proposals aimed at simplifying reporting requirements (e.g. simplified standards and more flexible rules for making estimates).
- Some of the new requirements will become mandatory from the 2027 financial year at the earliest, and reports on them will be drawn up in 2028.
- At the same time, sector-specific or product-specific regulations are already coming into force (e.g. packaging, batteries, single-use plastics), some of which require immediate evidence.
This means that sustainability reporting in 2026 will still be shaped by transitional arrangements. However, companies should not wait and see, but should establish processes and responsibilities now.
The most recent proposals and drafts focus on the following points:
- Dual materiality: clearer rules on which aspects are financially material and which are material to stakeholders
- Data collection: simplified rules for data collection and greater flexibility in estimating missing values
- Industry comparison: the use of benchmarks can support estimates and facilitate plausibility checks
These changes reduce complexity but increase the need for reliable processes. That is why, in 2026, sustainability reporting will be less a question of technology than of organisation.
The most common cause of delays is a lack of process structure. A pragmatic approach to sustainability reporting:
- Stock-take: What data is already available? (Energy, water, waste, HR figures, packaging)
- Defining responsibilities: Who is responsible for what, to what standard, and by when?
- Data collection and verification: standard formats, documentation requirements, plausibility checks
- Reporting: Narratives, key performance indicators, internal approval processes
- Publication and archiving
Without documentation of this workflow, sustainability reporting in 2026 will remain inefficient and prone to errors.
A well-structured organisational chart prevents last-minute, reactive data collection just before a deadline. Recommendations:
- Draw up a sustainability organisational chart down to the level of data providers (e.g. Facility Management, Vehicle Fleet, HR, Procurement).
- Define data owners for each key figure (e.g. electricity bill = Facilities, CO₂ fleet = Fleet Manager).
- Appoint a central coordinator or Head of Sustainability Reporting to oversee reporting deadlines and quality.
When it comes to sustainability reporting in 2026, the rule is: figures are essential, but they must be accurate and transparent. Practical guidelines:
- Create standardised templates for billing data (energy, heating) and consumption figures.
- Making the most of automation: Importing invoice data via an interface rather than manually uploading it to Excel.
- Document valuation methods: which assumptions were made, which sources were used, and when peer benchmarks were applied.
- Version control and approval: Every change to data must be documented in a way that allows it to be traced.
Scope 1 and 2 can usually be managed internally. Scope 3 is the challenge: the data comes from third parties. Procedure:
- Prioritise Scope 3 categories according to relevance and materiality.
- Create standardised supplier enquiries and requirements (e.g. emission factors, material origin).
- Where possible, include reporting obligations in procurement contracts.
- Use industry benchmarks if supplier data is missing.
The issue of the supply chain makes it clear that sustainability reporting in 2026 is often a collaborative process and requires coordination between legal and commercial departments.
Alongside the comprehensive sustainability report, there are product-specific guidelines:
- Packaging Ordinance: Demonstrate recyclability and comply with testing requirements.
- Battery Regulation: Take-back logistics, material declarations.
- Regulations on single-use plastics: labelling and records of quantities.
Some of these obligations come into force earlier – even for smaller companies – and require hard facts rather than merely narrative statements. That is why product compliance forms part of the reporting portfolio.
Small and medium-sized enterprises (SMEs) face a choice: build up in-house or external tools Use. Options:
- Use-case-based tools: standard templates, data import and report export.
- Industry and association solutions: benchmarks and simplified reporting processes.
- Standard frameworks for SMEs: digital support solutions and simplified questionnaires.
Even though sustainability reporting will often remain voluntary for SMEs in 2026, early digitalisation brings efficiency and future legal certainty.
A concrete roadmap for next year, if you are serious about sustainability reporting in 2026:
This checklist helps to ensure that sustainability reporting in 2026 does not turn into a last-minute rush job.
Common shortcomings in the reporting process and measures to address them:
- Lack of accountability: leads to gaps. Solution: data owners defined in the organisation chart.
- Unclear data definitions: differing interpretations make comparison difficult. Solution: a data dictionary.
- Over-reliance on manual Excel processes: prone to errors. Solution: automated interfaces and validation rules.
- Procrastination: Waiting for the final legal act leads to time pressure. Solution: Establish flexible processes that allow for subsequent adjustments.
Addressing these issues at an early stage reduces the need for subsequent corrections and minimises reputational risks.
Sustainability measures are not merely a cost factor. Examples of real-world effects:
- Energy efficiency measures with a short payback period improve profitability and reduce the carbon footprint.
- Better data quality reduces audit risks and simplifies certification processes.
- Supplier engagement increases resilience and reduces dependence on raw material supply chains.
This makes it clear that sustainability reporting in 2026 can deliver economic benefits if it is integrated into corporate strategy and investment planning.
FAQ in a nutshell – the most important questions and answers
Who will be required to produce a sustainability report in 2026?
The requirements primarily apply to very large companies, although the exact thresholds and timelines will depend on the final transposition into national law. Many other companies are initially affected on a voluntary basis, but may be indirectly affected through supply chain requirements.
What key performance indicators should a company be able to provide by 2026?
At a minimum: Scope 1 and 2 emissions, material Scope 3 categories, energy and water consumption, waste volumes, the recyclability of packaging, and information on governance and responsibilities.
Are estimates sufficient, or does all the data need to be backed up by precise evidence?
Modern approaches allow for greater flexibility in estimation, provided that the methodology is transparently documented and plausibly justified. Where possible, estimates should be supported by benchmarks or verifiable assumptions.
How should I handle Scope 3 data from suppliers?
Start with the categories that are most material; use standardised questionnaires, contractual requirements and industry benchmarks. Prioritise rather than asking for everything at once.
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