Pérez-Llorca and IE Examine the New European Sustainability Regulatory Framework

Pérez-Llorca hosted a new session of the Pérez-Llorca/IE Chair in Madrid entitled "The Reform of the CSRD and CSDDD Directives: A New Framework for Sustainability Reporting and Corporate Due Diligence." The event examined the legal landscape 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, Partner in ESG and Climate Change Regulation at Pérez-Llorca, and featured Ana Puente, Deputy Director General for Sustainable and Digital Finance at the Ministry of Economy, Trade and Business; Santiago Durán, President of the Institute of Accounting and Auditing of Accounts (ICAC); Juan Carlos Delrieu, Director of the ESG Office at Bank of Spain; Marco Masip, Director of ESG Strategy and Reporting at Telefónica; and Sara Sánchez, Associate Professor and Head of the Private Law Department at IE Law School.

During the session, participants analyzed how Directive 2026/470 narrows the scope of certain corporate sustainability obligations and introduces significant changes affecting the availability and quality of sustainability information. The discussion focused on the simplification of the CSRD and CSDDD frameworks and the substantial reduction in the number of companies subject to reporting requirements.

The panel also examined the technical and legal consequences of the reform. Santiago Durán noted the risks associated with revising a regulatory framework before its full implementation, highlighting concerns regarding the system’s ability to provide a true and consistent representation of sustainability information in light of the reduced scope and verification requirements.

Sara Sánchez addressed the legal implications of the reform for corporate due diligence and emphasized that the simplification process results in a significant reconfiguration of the civil liability regime. She noted that the fragmentation of applicable rules may increase complexity and legal uncertainty for companies.

Participants also discussed the consequences of the reduced regulatory perimeter, which could place the number of companies required to report sustainability information within an estimated range of 300 to 600 entities. They agreed that successive regulatory changes introduced before the original framework had been fully implemented have generated uncertainty and complicated corporate planning.

Juan Carlos Delrieu highlighted the implications that reduced information availability may have for financial supervision and risk management. He stressed that simplifying sustainability disclosures should not be interpreted as deregulation and that reduced corporate reporting may limit the data available to banks for identifying, measuring and managing risks, with potential consequences for financial stability.

Marco Masip emphasized the importance of ensuring that reporting frameworks meet the practical needs of stakeholders and provide meaningful value to organizations. He noted that the key challenge is not only the volume of information reported, but also its usefulness for those who rely on it.

The discussion also underscored the need to advance reporting models that ensure useful information, proportional obligations and legal certainty for all stakeholders involved.

Ana Puente focused on the role of public-private collaboration in implementing the European sustainable finance framework in Spain. She stated that sustainable finance is a tool for transforming the real economy in response to climate risks and strengthening corporate competitiveness. She also noted that, despite the reduction in the number of companies required to report sustainability information following the Omnibus outcome, incentives and mechanisms can encourage voluntary reporting where a clear benefit exists. As an example, she referred to Eco-Track, an initiative launched within the Sustainable Finance Council that helps SMEs identify sustainability information relevant to financial institutions seeking to meet supervisory expectations regarding climate-risk management in their loan portfolios.

The session further explored the role of voluntary reporting standards and the need to develop guidance and incentives that facilitate the production of useful, comparable and proportionate information for companies that will fall outside the new regulatory perimeter.

Through the Pérez-Llorca/IE Chair, Pérez-Llorca reaffirmed its commitment to supporting clients in navigating regulatory compliance and addressing key European Union regulatory developments.
 
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