NBIM Calls for Single EU Sustainability Report to Meet ESRS and ISSB Rules

NBIM says closer ESRS and ISSB alignment would help companies avoid dual reporting and reduce compliance costs.
The investor manages Norway’s $2 trillion oil fund, with €232 billion invested across 1,080 companies in the EU.
The recommendation comes as the EU revises ESRS under its Omnibus simplification agenda, which has already cut CSRD scope by 90%.

NBIM Pushes for One Report, Not Two

Norges Bank Investment Management is urging the European Commission to make sustainability reporting simpler for companies and more useful for global investors.

The manager of Norway’s $2 trillion oil fund said companies should be able to meet both European Sustainability Reporting Standards and International Sustainability Standards Board requirements in a single report.

The call came in NBIM’s response to the European Commission’s consultation on revised ESRS. The standards are being reshaped under the EU’s Omnibus I package, which aims to reduce reporting burdens while keeping core sustainability data intact.

For investors, the issue is comparability. NBIM said closer alignment between ESRS and ISSB standards would make it easier to compare European companies with peers in other jurisdictions. For companies, it would reduce the cost and complexity of producing separate disclosures for different regimes.

“The draft is a step forward but true simplification means one report, not two. That means aligning European standards with the International Sustainability Standards Board (ISSB) Board Standards, the global baseline adopted in over 40 countries. We believe a few targeted reforms can deliver this and companies, investors and European capital markets all stand to gain.” said Carine Smith Ihenacho, Chief Governance and Compliance Officer at NBIM.

Carine Smith Ihenacho, Chief Governance and Compliance Officer at NBIM

EU Reporting Rules Enter a New Phase

The European Commission released the new draft ESRS last month. It is one of the final major steps in the EU’s effort to simplify sustainability reporting under the Omnibus I initiative.

The Omnibus package has already narrowed the scope of the Corporate Sustainability Reporting Directive. EU lawmakers approved changes that removed companies with less than €450 million in revenue and 1,000 employees from CSRD requirements. The previous threshold was 250 employees.

The change reduced the number of companies covered by mandatory reporting by about 90%.

The revised ESRS are based on technical advice from the European Financial Reporting Advisory Group. EFRAG submitted its final proposed revision in December 2025. The proposal cut mandatory datapoints by 61% and removed all voluntary disclosures. In total, datapoints were reduced by more than 70%.

NBIM supports the simplification push. But it said simplification should not come at the expense of global consistency.

ISSB as the Global Baseline

NBIM said the ISSB standards have become the global baseline for sustainability reporting. It noted that about 42 jurisdictions have adopted the standards, representing around 60% of global GDP.

The ISSB issued its first general sustainability and climate reporting standards in June 2023. IFRS S1 focuses on sustainability-related risks and opportunities. IFRS S2 focuses on climate-related disclosure.

Both are designed to provide investors with financially material information.

NBIM said the EU can still preserve its double materiality model while aligning more closely with ISSB. Double materiality requires companies to report both how sustainability issues affect the enterprise and how the enterprise affects people and the environment.

“Were the EU to build on the ISSB model, it could continue to pursue its double materiality objectives while keeping the financially material information investors need comparable across frameworks.”

That distinction matters for capital markets. Global investors need consistent data across regions. Companies need a reporting system that does not duplicate work or create conflicting formats.

Technical Fixes for Single-Report Compliance

NBIM recommended two targeted technical amendments.

The first is a non-obscuring principle. This would require investor-relevant information in a sustainability statement to be clearly identifiable. It should not be buried by disclosures aimed at other audiences.

The second is flexibility in presentation format. This would allow companies to structure disclosures in a way that supports compliance with both ESRS and ISSB standards.

NBIM also urged the Commission to avoid new changes that reduce interoperability with ISSB. It warned against extending the commercial prejudice exemption to anticipated financial effects. In NBIM’s view, that could allow companies to withhold figures on exposure to climate-related physical and transition risks.

The fund manager also questioned a phase-in that would let companies defer quantitative disclosure of non-climate anticipated financial effects until FY2030. NBIM said this would create a gap with ISSB Standards, which require the disclosure from year one.

What Investors Should Watch

NBIM’s response goes beyond climate reporting. It also calls for IFRS industry-based guidance, including SASB Standards, to be referenced in the ESRS double materiality assessment.

The investor said this would help companies identify industry-specific sustainability issues that affect financial performance.

NBIM also urged the Commission to work with the ISSB on nature-related disclosures. The ISSB is developing a nature-related IFRS Practice Statement, drawing on the TNFD framework. An exposure draft is expected by COP17 in October 2026.

For executives, the takeaway is practical. The next version of ESRS will shape not only compliance costs, but also how investors judge resilience, transition planning, and exposure to sustainability risks.

For the EU, the stakes are broader. Europe wants to preserve its leadership on sustainability disclosure. But it also needs reporting rules that do not isolate its companies from global capital markets.

NBIM’s message is clear: European ambition and global comparability do not need to compete. If the Commission gets the final technical design right, companies may be able to report once and meet both.