Five ESG Decisions That Strengthen Your Strategy

The ESG conversation changed in 2026 and a lot of published advice has not caught up with it.

What changed, and why it matters to your strategy

The EU’s Omnibus I directive, published in the Official Journal on 26 February 2026, raised the Corporate Sustainability Reporting Directive threshold to companies with more than 1,000 employees and net turnover above €450 million, both conditions required together. That cut the number of companies in scope from roughly 50,000 to around 5,000. Source: Council of the European Union, consilium.europa.eu. The narrowed scope applies to financial years beginning on or after 1 January 2027, and several member states have yet to transpose it, so confirm your own position. We set out the detail in our guide to integrating CSR into your business model.

If you are out of scope, the pressure on ESG now comes from customers, lenders, investors and tender processes rather than from an auditor. That is a different kind of pressure. It is less prescriptive and considerably less forgiving of vague claims, because the people applying it are comparing you against a competitor rather than against a standard.

1. Decide why you are doing this before you decide what to measure

There are three honest answers and they lead to different strategies. You are answering procurement questionnaires and tenders. You are answering lenders or investors. Or you have a genuine commitment and want it run well. Most companies are doing some mix, but one usually dominates.

Say which it is internally. A programme built to win public sector tenders needs evidence in the format buyers ask for, which is not the same thing as a programme built around a founder’s commitment to a cause. Companies that skip this step end up producing material that satisfies nobody.

2. Pick fewer measures than feels comfortable

A long list of indicators looks thorough and is usually a sign that nobody decided what mattered. Six measures you report accurately every year beat thirty you report once.

Choose ones where you can actually get the data without a special project each time. If a figure requires someone to spend a fortnight chasing it, it will be reported late, then approximately, then not at all.

3. Put a named person on each commitment

Governance is the pillar companies find easiest to write about and hardest to demonstrate. The practical test is not whether you have a board committee. It is whether every published commitment has one person accountable for delivering it and a date by which they are expected to.

Where decisions involve allocating money, conflicts of interest need declaring and recording. That applies as much to a £5,000 community fund as to a procurement decision, and it is the first thing anyone auditing the programme will look for.

4. Run the social commitments as programmes, not gestures

The S is where most companies have the widest discretion and the weakest process. Community funds, social value commitments attached to public contracts, employee-nominated donations and partnerships with local organisations all involve deciding who gets money and being able to explain why.

Run that the way a funder would. Publish eligibility criteria and exclusions. Keep the application proportionate to the sum involved, because a demanding form on a small grant excludes precisely the small organisations a community fund exists to reach. We looked at how that plays out in the barriers social work organisations face when applying for grants. Score applications against written criteria. Keep a record of decisions.

This is also the part that produces defensible numbers. “We supported the community” is not evidence. Applications received, organisations funded, amount distributed, geographic spread and proportion of first-time recipients are.

5. Report the misses alongside the hits

A report where every target was met reads as selective, because it almost always is. Naming a target you missed, with the reason and what you changed, does more for credibility than another page of achievements. Tender evaluators and lenders read a lot of these and they notice which ones only contain good news.

Where does Submit.com fit?

Submit.com is not ESG reporting software and does not calculate emissions or produce ESRS disclosures. What it does is run the application and assessment side of the programmes that sit under the social pillar: community funds, social value commitments, employee-nominated giving and sponsorship schemes.

That means a configurable form with eligibility rules built in, weighted scoring against criteria you set, role-based permissions and separation of duties so the decision record stands up, and reporting that exports to CSV or through the API when the figures are needed for a tender response or an annual report. If your company runs a fund of any size, grant management software is the category to look at.

Frequently asked questions

What is the difference between ESG and CSR?

CSR is the voluntary activity a company undertakes for social or environmental benefit. ESG refers to the environmental, social and governance data a company discloses so that investors, lenders and buyers can assess it. CSR describes what you do; ESG describes what you can evidence.

Is ESG reporting still mandatory in the EU?

Only for the largest companies. The Omnibus I directive raised the CSRD threshold to more than 1,000 employees and net turnover above 450 million euro, with both required, reducing the number of companies in scope from roughly 50,000 to around 5,000. The narrowed scope applies to financial years beginning on or after 1 January 2027.

Should we keep reporting voluntarily if we are out of scope?

It depends on who asks you for the data. If you bid for public contracts, or borrow from lenders with sustainability conditions, or supply large companies that remain in scope, you will be asked regardless of your own obligation. In that case voluntary reporting is a commercial requirement under a different name.

How do we evidence the social pillar credibly?

Run your community investment as a structured programme with published eligibility criteria, applications assessed against written criteria, and a record of every decision. That produces countable figures such as applications received, organisations funded and amount distributed, which are far more persuasive than descriptive claims about supporting the community.