Mind the data gap: Are investors getting what they need?

High-quality data is essential for investors as they develop strategies and set climate targets. However, the recent EU omnibus proposals have raised concerns that access to corporate data could be significantly reduced as part of a broader efforts to streamline reporting. Using voluntary disclosure frameworks developed by IIGCC as a reference point, we have reviewed the main climate disclosure frameworks, including ESRS, to assess the extent to which they provide investors with the information necessary to meaningfully evaluate corporate transition efforts.  

The shift towards mandatory, comprehensive disclosures has created an opportunity to close data gaps for investors. In the EU, the development of the European Sustainability Reporting Standards (ESRS) – which underpin the Corporate Sustainability Reporting Directive (CSRD), and specifically the climate-focused ESRS-E1 – raised expectations that high-quality, consistent reporting would soon be available.  

However, the European Commission’s proposed changes to the CSRD - set out in the March 2025 “Omnibus proposals”— signal a significant shift in direction, with changes that could substantially weaken the framework’s scope and impact. Proposals include increasing the company size threshold for reporting from 250 to over 1,000 employees, with some discussions suggesting further increases to 3,000 or even 5,000 employees. If implemented, these changes would exempt an estimated 80% of companies currently covered and reduce mandatory datapoints by up to 70%. Such a rollback would greatly diminish corporate reporting transparency and reverse momentum at a time when robust climate data is crucial for informed investor action. 

Data that matters 

While the interest to streamline reporting requirements is understandable, preserving – and, where necessary, strengthening – core datapoints must remain a top priority. Investors must clearly articulate their critical data needs, and regulators should ensure these needs are reflected in the evolving disclosure landscape.  

Reducing the reporting burden should not come at the expense of the material information that enables investors to understand climate-related risks and opportunities, or to allocate capital to the sectors and technologies essential for a successful transition. 

To support this effort, IIGCC has mapped the ESRS-E1 against the core components of credible transition plans identified by our members, guided by the Climate Action 100+ Net Zero Company Benchmark and the Investor Expectations of Corporate Transition Plans, as well as a sector-neutral transition plan framework. Beyond climate, the tool also assesses ESRS-E4, which addresses nature and biodiversity reporting, guided by the Nature Action 100 Company Benchmark. 

This analysis provides a snapshot of the alignment and gaps between existing reporting requirements and the most valuable, usable information investors need. 

This mapping also served as the foundation for our recent response to the European Financial Reporting Advisory Group (EFRAG) consultation. 

Our findings 

The good news is that there is a strong degree of alignment between investor expectations and the existing ESRS-E1 requirements. For example, E1-4 34 provides strong support for comprehensive target-setting across emissions scopes 1, 2 and 3, and requires companies to assess their alignment with a 1.5°C scenario. Equally important, several ESRS metrics emphasise the need to quantify the levers a company intends to use to achieve these targets. In areas such as energy consumption and carbon lock-in, the ESRS goes further than existing voluntary frameworks. Collectively, these metrics will generate valuable data that investors can use to assess transition risks at both the asset and portfolio levels.  

However, the exercise also revealed two critical gaps: 

1. The lack of mandatory short-term emissions reduction targets. While long-term goals are vital, short-term targets are needed to ensure that boards and management are actively steering towards decarbonisation. 

1. Insufficient disclosure around companies’ lobbying activities—especially in relation to whether these activities align with the goals of the Paris Agreement. Although ESRS-E1 includes limited provisions around how companies exert influence on material risks, it stops short of requiring comprehensive transparency on lobbying.  A company’s external engagement—whether through industry groups or direct advocacy—can be a key metric for investors assessing its climate commitments.  

Read our memos on corporate climate policy engagement supported by InfluenceMap 

Beyond ESRS – pursuing interoperability 

A core value of this tool is its scope beyond just EU standards. Our mapping also analyses criteria against the ISSB standards and the Transition Plan Taskforce (TPT) framework.  

To meaningfully reduce reporting burdens and streamline disclosure requirements for investors, alignment and interoperability must be prioritised. Comparable and consistent guidelines across disclosure frameworks will enable investors to assess holdings globally on a like-for-like basis, while also streamlining reporting obligations across their portfolios. 

We encourage our members to contribute to this work. Input on which data points are most useful—and where gaps remain—is essential for shaping a coherent investor voice in policy and regulatory discussions. If you would like to share your reflections, please contact Dan Gardiner.