The ISSB Is Now the Global Baseline. Here's What That Means If You Supply the Companies Who Have to Report.

Two things are happening in sustainability reporting at the same time, and they look like they point in opposite directions.

The first: the rulebook is consolidating. The International Sustainability Standards Board (ISSB), created by the IFRS Foundation in late 2021, has quietly become what investors and regulators now openly call the global baseline for sustainability disclosure. Norway's $2 trillion sovereign wealth fund, NBIM, put it plainly in its June 2026 response to the European Commission: the ISSB standards “have become the global baseline,” with adoption underway in more than 40 jurisdictions representing roughly 60% of global GDP.

The second: companies are talking about sustainability less. According to Trellis's State of the Sustainability Profession 2026, 63% of companies have scaled back their sustainability communications or rethought how they talk about the work. Priorities are shifting under the surface, too: 58% are putting a higher priority on compliance, while 53% say social issues now matter less to them than they did.

Put those together and you get the real story of 2026: sustainability hasn't gone away. It's gone quieter, more technical, and more tightly bound to regulation, risk, and the data your customers demand from you. For mid-market manufacturers, especially those supplying the big consumer brands, that combination is easy to misread. So let's unpack it.

The "green hush" is a strategy shift, not a retreat

The pullback in public sustainability messaging has a name now, the “green hush,” and the Trellis numbers show how widespread it's become. But scaling back the communications is not the same as scaling back the work. When 58% of companies say compliance is now a higher priority, what they're really telling you is that sustainability has moved out of marketing and into finance, procurement, and risk management.

And that's the right place for it. Reporting and disclosure aren't about “storytelling,” and they haven't been for a long time. The frameworks driving this work (ISSB, CSRD, ESRS) exist to put auditable, decision-useful data in front of investors, regulators, and customers, not to generate a narrative. The companies quieting their public messaging aren't losing conviction; they're recognizing that a verified number carries more weight than a well-written claim, and acting accordingly.

That's a meaningful change. A press release about a recycled-content goal is optional. A verified GHG inventory that a major customer requires before renewing a contract is not. The center of gravity has shifted from voluntary claims to mandatory, auditable data, and the companies that quietly built the underlying infrastructure are the ones now able to answer those requests without scrambling.

What the ISSB baseline actually is

The ISSB framework rests on two standards issued in June 2023: IFRS S1, which sets the general requirements for disclosing material sustainability-related risks and opportunities, and IFRS S2, which adds climate-specific requirements like transition plans, scenario analysis, and climate metrics drawing on the industry-specific SASB guidance underneath it.

The key thing to understand about ISSB is its lens. It's built around financial materiality: it asks what sustainability issues could reasonably be expected to affect a company's cash flows, access to finance, or cost of capital. That single-materiality focus is exactly why investors like it, it speaks their language, and it's a big reason jurisdictions from the UK to across Asia and the Middle East are aligning their own regimes to it. The baseline is spreading because capital markets are standardizing around it.

CSRD and ESRS aren't going away, but the goal is to report once

Europe took a different path. The Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) are built on double materiality: both the financial risks sustainability poses to the company and the company's impacts on people and the planet. That broader scope is the EU's deliberate design choice, and the European Commission has so far resisted simply folding ISSB reports into the ESRS. The Commission hasn't spelled out its reasoning, but observers attribute the reluctance to a desire to protect double materiality as a single, integrated assessment, rather than letting it become financial materiality with an impact layer added on afterward.

But the two frameworks are converging fast on the practical question that matters to preparers: do I have to do this twice? The answer, increasingly, is no, if you build your reporting the right way.

A few developments are pulling in that direction:

• The ESRS themselves are getting leaner. Under the EU's Omnibus simplification package, EFRAG's revised draft ESRS cut mandatory datapoints by roughly 61% and removed voluntary disclosures entirely, which is a total reduction of more than 70%. Less duplication, fewer datapoints, more overlap with what ISSB already asks for.

• The standard-setters are aligning terminology. The revised ESRS include amendments that bring wording and metrics closer to ISSB on the same topics, and the ISSB and EFRAG have published interoperability guidance mapping where their climate disclosures already agree.

For a reporting company, the practical takeaway is this: design your sustainability data architecture around the overlap first. Build one rigorous, assurance-ready foundation (a solid GHG inventory across Scopes 1, 2, and 3, consistent metric definitions, traceable data sources), and then map it to each framework's specific requirements rather than running two parallel exercises. EY's 2026 CSRD Barometer found that second-year ESRS reporters produced shorter, more focused, better-assured statements largely because they finally had that foundation in place. The first year is the heavy lift; interoperability is what keeps year two from being a second heavy lift.

It's worth flagging one moving piece: assurance. Limited assurance over the full sustainability statement is now the European market standard, and the assurance world is transitioning from ISAE 3000 to the new ISSA 5000 standard for periods starting in late 2026. Whichever framework you report under, the data behind it increasingly has to withstand an auditor's review, which raises the bar on documentation and data quality well before any report is published.

The part most mid-market manufacturers miss: you don't have to be regulated to be on the hook

Here's where a lot of mid-market companies quietly relax when they shouldn't.

The EU's Omnibus package cut the number of companies directly caught by CSRD by about 90%, removing those below roughly €450 million in revenue and 1,000 employees, and "stopping the clock" so that many large non-listed undertakings now don't report until periods starting in 2027. If you're a $20M–$500M manufacturer, there's a good chance you read that and concluded the whole thing no longer applies to you.

It doesn't apply to you directly. But your customers are a different story.

When L'Oréal, Unilever, or Estée Lauder build their disclosures — whether under ESRS, ISSB, or both — the single largest piece is almost always Scope 3. EY's analysis confirms what every supply-chain professional already knows: corporate Scope 3 emissions are dominated by purchased goods and services (Category 1) and the use of sold products (Category 11). In plain terms, your product is their Scope 3. They cannot close their own carbon books without data from you.

That's why the requirements flow downhill regardless of who's technically in regulatory scope. It shows up as:

• Requests for product-level carbon footprints and life cycle assessments (LCAs) so a brand can substantiate its own claims and Scope 3 numbers.

• EcoVadis assessments and CDP supply-chain questionnaires arriving as a condition of staying on an approved-supplier list.

• Pressure to produce a credible GHG inventory and, increasingly, ISSB- or ESRS-aligned data points your customer can drop straight into their disclosures.

A supplier who can hand over clean, verified, framework-aligned data becomes easier to keep on the roster, and harder to replace. A supplier who can't becomes a gap in the customer's report, which is the kind of gap procurement teams are now actively closing.

Where this leaves you

The landscape in 2026 rewards companies that treat sustainability as data infrastructure rather than messaging. The ISSB baseline is making that data more standardized and more portable across markets. CSRD and ESRS are converging toward it, so a well-built foundation can increasingly serve both. And the requirements are reaching far past the companies named in any regulation, pulled through global supply chains by the customers who are named.

For mid-market companies, the strategic move isn't to wait and see whether a rule lands on you. It's to get the underlying data right: a defensible GHG inventory, product LCAs your customers can use, strong EcoVadis and CDP submissions, and disclosure-ready reporting, so that whichever framework your biggest customers report under, you're an asset to their numbers instead of a question mark.

 That groundwork is exactly the kind of work we do at ADB Sustainability. If your customers have started asking harder questions, or you suspect they're about to, we'd be glad to talk through where to start.

ADB Sustainability helps mid-market manufacturers build the carbon accounting, LCA, EcoVadis, CDP, and ESG reporting infrastructure their customers and regulators increasingly expect. Get in touch.