Beyond compliance: Using the CSRD principles to sharpen our impact strategy

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The introduction of the Corporate Sustainability Reporting Directive (CSRD) has prompted many organisations to reassess how they approach sustainability, transparency, and accountability. Although VP Capital ultimately falls outside the final scope of the CSRD following the Omnibus I decision in December 2025, the preparation process proved to be highly valuable.

Rather than viewing the CSRD purely as a compliance exercise, we used it as an opportunity to sharpen our impact-first strategy and deepen our understanding of what truly matters – for our organisation, our portfolio, and our stakeholders. In this Insight, we share the key steps we took, the choices we made, and the lessons we learned along the way.

Throughout this journey, we were supported by Pantarein, a sustainability consultancy specialising in impact strategy and reporting. Their external perspective helped us challenge assumptions, structure the process, and translate regulatory requirements into strategic insight.

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The CSRD in brief – and why we prepared anyway

The CSRD is part of the European Green Deal and aims to improve the quality, consistency, and comparability of sustainability reporting across Europe. Under the original scope, companies meeting a certain size criteria were required to report on sustainability as part of their annual reporting, in line with the European Sustainability Reporting Standards (ESRS). In addition, the directive is intended to encourage and stimulate greater investment in sustainable activities and businesses by increasing transparency and enabling better-informed capital allocation decisions.

Based on the initial criteria, VP Capital prepared to report under the CSRD from the 2025 financial year onwards. However, following the final vote in December 2025, the scope was significantly narrowed. Only companies with more than 1,000 employees and over €450 million in net turnover now fall within scope, with reporting obligations starting from financial year 2027 under simplified standards. As a result, VP Capital no longer meets the revised thresholds and is not legally required to report under the CSRD.

By the time this decision was taken, we had already made substantial progress in our preparations. We therefore chose to continue working with key CSRD principles, as they align well with our impact-first strategy and our ambition to report transparently.

The double materiality analysis as a starting point

At the heart of the CSRD lies the double materiality analysis (DMA). This analysis identifies which sustainability topics are most relevant by assessing them from two perspectives:

Impact materiality: how an organisation impacts people and the planet (inside-out).
Financial materiality: how sustainability topics create risks and opportunities for the organisation (outside-in).

For VP Capital, the DMA was not only a regulatory requirement but also a strategic exercise. It offered a structured way to validate whether the topics we focus on are indeed the ones that matter most.

As Katelijne Norga, CEO of Pantarein, reflects: “A well-executed double materiality analysis is not about ticking a regulatory box. It’s about creating a shared understanding of where an organisation truly has impact, risk, and responsibility – and using that insight to guide decision-making.”

The double materiality analysis (DMA) helps determine the most relevant sustainability topics.

A structured and inclusive process

The DMA followed a multi-step approach, combining internal insight with external perspectives: internal interviews with key team members, strategic workshops, surveys among external stakeholders, and in-depth interviews with employees, non-governmental organisations, peers, and experts in areas such as regenerative agriculture and impact investing.

The topics assessed were derived from the ESRS framework and covered environmental, social, and governance standards, including climate change, biodiversity, circularity, working conditions, and business conduct.

An important role of Pantarein in this phase was to act as an independent facilitator – ensuring methodological rigour while leaving room for open dialogue.

Defining the scope: Four distinct activities

VP Capital operates as a family office with consolidated entities, each with very different activities. To reflect this diversity, we carried out separate DMA for VP Capital (family office activities, including investments), VP Textile, VP Landbouw, and VP Vastgoed. This resulted in four individual materiality matrices rather than a single aggregated one. For VP Textile, the process ran in parallel with active involvement from the CEOs of HAVEP, Van Heurck, and Hydrowear, reflecting the operational nature of that business.

The analyses revealed that, at the family office level, the main sustainability priorities were climate, employees, and business conduct. For VP Landbouw, the most material topics were pollution, biodiversity, land use, and water. VP Vastgoed, which manages both our direct real estate investments and our participations in real estate funds, must address land use, climate, and value chain impacts, while VP Textile must concentrate on biodiversity, pollution, value chain workers, and circularity.

From four matrices to a workable focus

Reporting on all material topics across all entities would have resulted in an overly broad and impractical report. The next step was therefore consolidation.

We benchmarked our approach against other long-term investors and family offices, including Ackermans & van Haaren, Gimv, and Sofina. A clear pattern emerged: they primarily report on their own operations and on their role as responsible investors, rather than on the full operational detail of every underlying investment.

Building on this insight, we:

created a consolidated view across the four analyses
raised the materiality thresholds to identify the most critical topics shared across the group
focused on topics that are meaningful both for our own activities and for our role as an investor

 As Katelijne Norga notes:

“Consolidation is where many organisations struggle. The challenge is to remain faithful to the analysis, while still arriving at a set of topics that is clear, credible, and workable.”

Katelijne Norga, CEO of Pantarein

The resulting focus areas

Following this exercise, we identified four core topics that we consider most relevant to report on:

Climate, in line with ESRS E1: focusing on the GHG emissions relevant to our family office, our consolidated entities and our investments, given its significance as a pillar of our impact-first strategy.
Working conditions of our own employees, in line with ESRS S1: centred on the mental and physical wellbeing of employees in our family office and our consolidated entities.
Business conduct, in line with ESRS G1: with an emphasis on integrity and transparency as the cornerstones of our policies across our family office, VP Vastgoed, and VP Textile.
Responsible investing, as an entity-specific topic reflecting our role as a family office and long-term investor.

These topics allow us to clearly distinguish between our own organisational practices and how we deploy capital and engage with our portfolio. 

From materiality to action: Gap analysis and continuous improvement

Identifying what is material was only the starting point. As Michel Meerkerk reflects: “The CSRD exercise has helped us sharpen our focus and improve the coherence of our ESG management and reporting. Even outside the formal scope of the directive, we see the CSRD as a useful compass that strengthens our accountability and supports continuous learning - both within VP Capital and beyond.”

As Katelijne Norga explains: “The real value of the CSRD lies in what organisations do after the materiality assessment. Continuous improvement starts when insights are translated into concrete priorities and actions.”

By treating materiality as a dynamic process rather than a static outcome, we aim to move beyond a box-ticking approach and embed learning and improvement over time.

Michel Meerkerk, Director Finance & Legal VP Capital

Looking ahead: the CSRD as a strategic tool

Although VP Capital is no longer required to report under the CSRD, the process has delivered lasting value. The double materiality analysis and external expert input strengthened internal dialogue, challenged assumptions, and brought more transparency to our material topics in our Impact Report.

 For other family offices and impact investors, our key takeaway is clear: the CSRD can be more than a compliance exercise. When approached thoughtfully and supported by external expertise, it becomes a strategic tool to sharpen focus, improve transparency, and align sustainability reporting with long-term purpose to seek continuous improvement.

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Beyond compliance: Using the CSRD principles to sharpen our impact strategy

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