Festraets, Cerise (2026) Did Omnibus I lead to more bottom-up governance in large-scale companies’ risk management? Bachelor thesis, Global Responsibility & Leadership (GRL).
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Abstract
Corporate sustainability disclosure is a central instrument of European Union climate policy, yet the Omnibus I revision (2025–2026) reversed course, sharply narrowing the Corporate Sustainability Reporting Directive (CSRD). This thesis asks how large Benelux companies that remain within the mandatory scope disclose sustainability risk management after the rollback, and what this reveals about their transition pathway. Combining the Multi-Level Perspective (MLP) on sociotechnical transitions with the top-down/bottom-up distinction from implementation research, it reads board-centred disclosure as regime reproduction and operationally integrated disclosure as niche practice. Using directed quantitative content analysis of 100 company-year reports from 50 firms across the 2025 and 2026 reporting years, the study finds a disclosure landscape that is hybrid in substance but top-down in emphasis, and largely stable across the two years. Most reports (82%) combine top-down and bottom-up features and none rely on bottom-up practices alone, yet responsibility concentrates in boards (94%) and executives (74%) over employees (64%) and suppliers (42%); explicit terminology rose only from 24% to 28%; framing was almost universally positive (96%); and the dominant response to Omnibus I was to maintain disclosure. Interpreted through the MLP, this represents regime reproduction carrying early, partial features of reconfiguration rather than a niche-led transition. The study contributes by combining two previously separate frameworks to read disclosure as evidence of a transition pathway.
| Item Type: | Thesis (Bachelor) |
|---|---|
| Name supervisor: | Schulz, K.A. |
| Date Deposited: | 23 Jun 2026 11:15 |
| Last Modified: | 23 Jun 2026 11:15 |
| URI: | https://campus-fryslan.studenttheses.ub.rug.nl/id/eprint/855 |
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