The Sillion Briefing 12.12.2025
A fortnightly digest for corporate sustainability & communications leaders
In this edition...
EU deal narrows CSRD/CSDDD scope; and delays
EFRAG drafts simplifies ESRS; cuts datapoints by 61%
ASA bans Nike, Superdry, Lacoste ‘sustainable’ ads
2026 Investor Sustainability Report
Sillion has released the 5th edition of its popular report into investor attitudes towards sustainability and disclosure - explaining what they want to see from companies in 2026. It can be accessed below.
EU strikes deal to scale back CSRD + CSDDD scope (and push timelines)
On December 9th, EU governments and the European Parliament reached a provisional deal to significantly narrow the scope of the CSRD and CSDDD. Under the deal, CSRD reporting would apply only to companies with more than 1,000 employees and net turnover above €450m (and to non-EU companies meeting an equivalent EU turnover threshold).
CSDDD would apply only to firms with more than 5,000 employees and €1.5bn net turnover (again including non-EU firms with that level of EU turnover). Potential fines for breaches would be capped at 3% of global turnover. The deal also delays CSDDD compliance to mid-2029 and drops the CSDDD obligation for climate transition plans.
Formal approval for the deal is still required - though this is generally procedural once a deal is reached.
Source: Reuters
Why this matters
The deal is in line with reported Omnibus developments over the past few months. If you’ve been building CSRD/CSDDD programmes, you may need to re-check scope, sequencing, and internal governance. But - don’t necessarily assume the data requests disappear (banks, customers, investors, and procurement can still drive “CSRD-like” asks).
EFRAG publishes “draft simplified ESRS” package
On December 3rd, EFRAG published a package of draft simplified European Sustainability Reporting Standards (“ESRS” – the reporting standards required of companies falling in scope of CSRD). In its cover letter to the European Commission, EFRAG says the amended standards introduce “substantial flexibility, reliefs and phasing in” and reduce mandatory "required if material" datapoints by 61%, while aiming to retain core Green Deal objectives and improve usability.
Source: EFRAG
Why this matters
This is an early signal of where ESRS might land after the Omnibus - useful for anyone still in scope, and also for anyone who expects ESRS-aligned requests from EU customers. A 61% datapoint reduction is meaningful, but doesn’t remove the need for a defensible materiality process, governance, and credible underlying data.
UK ASA bans Nike, Superdry, and Lacoste ads for “sustainable” claims
The UK’s Advertising Standards Authority (ASA) has banned paid Google search ads from Nike, Superdry, and Lacoste, after finding that broad sustainability claims (“sustainable”, “sustainable materials”, “sustainable style”) were ambiguous and inadequately substantiated, and therefore risked misleading consumers.
In Nike’s case, the ASA noted that while the company provided evidence that the relevant products contained high recycled-content materials, the ad’s wording was still an absolute environmental claim. And without clear qualification, it implied the product had no detrimental environmental impact across its life cycle, which Nike had not demonstrated. The ASA also referenced CMA guidance that broad claims like “sustainable” are likely to mislead unless clearly explained and evidenced.
Source: The Guardian
Why this matters
This is a clean reminder (especially for consumer brands) that regulators are testing whether you can prove what you imply, and that vague “sustainable” language is increasingly risky – particularly in search ads due to their brevity. If you want to use broad sustainable framing, you need (1) precise definitions, (2) lifecycle-aware evidence, and (3) copy that doesn’t overclaim. This is hard, and is a governance issue (marketing controls, sign-off, substantiation packs) as much as a comms issue.
Thank you for reading.
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