Building an ESG Career When the Rules Keep Being Rewritten
Anyone who built their professional identity around knowing the CSRD requirements in detail has had an unsettling eighteen months.
The Omnibus raised the scope thresholds to more than 1,000 employees and €450 million in net turnover, while the delayed second wave is now due to apply from financial years beginning on or after 1 January 2027. The revised ESRS adopted by the European Commission on 3 July 2026 cut mandatory datapoints by more than 60% and total datapoints by more than 70%. Elsewhere, deadlines have moved and requirements have been simplified. A substantial amount of hard-won specific knowledge became less relevant quite quickly.
I think the lesson is not that framework knowledge is worthless. It is that it depreciates, and a career built only on the depreciating asset is exposed.
The two kinds of expertise
Watching who has been unsettled by the last year and who has not, the pattern is fairly clear.
Framework expertise is knowing what a standard currently requires. It is valuable, it is in demand, and it is the fastest route into the profession. It also has a half-life. Every revision writes down part of it, and revisions are not slowing.
Process expertise is knowing how to make a number defensible. How to design a validation routine, how to build a reconciliation that catches a problem before an auditor does, how to structure ownership so every figure has a name against it, how to document a decision so it survives the person who made it.
Process expertise transfers. The reconciliation logic that worked for ESRS works for a customer questionnaire, an ISSB-aligned disclosure, or whatever the next framework asks for, because underneath every framework is the same question about whether the number can be trusted.
Frameworks tell you what good reporting must achieve. They do not design the control environment that gets you there, and that gap is where the durable skill lives.
What I have found worth investing in
Some of this is retrospective rationalisation, since I did not plan a career this way. But looking at what has kept its value:
Data governance fundamentals. Lineage, ownership, validation, reconciliation, change control. These are not sustainability concepts. They are borrowed from disciplines that worked them out decades ago, and they do not get revised when a delegated act is adopted.
Enough financial literacy to be understood. I took an online financial management course for exactly this reason. Double materiality asks, among other things, how sustainability-related risks and opportunities can affect financial performance, financial position, cash flows and access to finance. You cannot answer that credibly without reading financial statements comfortably. It is also, practically, how sustainability arguments get funded.
The ability to explain a method to someone sceptical. Assurance providers, auditors, customers running supplier diligence, and increasingly regulators. Being able to walk someone through how a figure was produced, without defensiveness, is a skill and it is rarer than it should be.
Judgment about what to estimate. Knowing when an estimate is appropriate, how to label it, what assumptions sit underneath it, and what would be needed to replace it. Frameworks can set requirements around estimates and uncertainty, but they cannot exercise that judgment on your behalf.
On the anxiety
I do not want to be glib about the insecurity in the profession at the moment. Roles have been affected by scope reduction, and some organisations have read simplification as permission to reduce sustainability capability. That is a real thing happening to real people, and telling them to develop transferable skills is not a complete answer.
What I would say is that the demand underneath has not moved as much as the regulatory surface. Companies below the new thresholds still receive sustainability data requests from customers and larger companies in their value chains. Banks still incorporate climate-related information into credit decisions and pricing. The GHG Protocol's Scope 3 revision work is moving towards more explicit treatment of data quality, even as the timetable has shifted into the joint GHG Protocol–ISO standard-setting process.
The direction of travel on provenance has been more consistent than the direction of travel on regulatory scope.
Some of the work appears to be shifting rather than disappearing. It is moving beyond dedicated compliance teams and into value chains, procurement functions, finance teams and companies that were never directly in scope at all.
The version of this I believe
The most durable position in this profession is not being the person who knows the current rules best. It is being the person who can be handed an unfamiliar set of requirements and build a process that produces defensible answers to them.
That capability was useful under the first-generation ESRS. It is useful under the revised ones. It will be useful under whatever comes next, and under the customer questionnaire that arrives from a company you have never dealt with in a format nobody standardised.
Frameworks are the current expression of a demand that has been remarkably stable: show us, and show us how you know.
That demand is what I would build a career on.
Working on something in this space? I'd be glad to compare notes. Get in touch.