The strategy stall: why good intentions aren’t translating into traction
Key takeaways:
Many sustainability strategies stall despite ambition and public commitments.
Common blockers: outdated plans, issue-focused structure, weak business translation, limited authority, reporting over delivery, and missing organisational capabilities.
Highlights how to identify gaps and guide your strategy toward real-world impact.
Sustainability teams are busier than ever. Strategies are in place, commitments are public, reporting cycles are running. And yet, things feel slow.
After a turbulent 2025 – regulatory shifts, political headwinds, evolving stakeholder expectations – many organisations are finding that strategies which felt robust even a year ago now feel out of step. It’s not for lack of effort or ambition. But somewhere between the strategy document and the day-to-day reality of the business, momentum has stalled.
If this sounds familiar, here are six places to look.
1. The strategy was built for yesterday's landscape
The regulatory and stakeholder environment has shifted dramatically. CSRD, ISSB, double materiality, transition planning requirements, enhanced assurance expectations — what counted as an enabling and credible strategy five years ago, or even last year, now has significant gaps.
Strategies built in that earlier era often share common features: broad focus and commitments, far-off target dates, and a focus on demonstrating direction rather than proving progress. That was appropriate for where we were. But expectations have moved on.
What’s now required is different: strategies grounded in issues that genuinely protect or create value, with quantified pathways, auditable data, and disclosure that connects sustainability performance to business performance.
The gap between “we have a strategy” and “we have a strategy that we can credibly deliver” is where many organisations are stalling. And without closing that gap, teams find themselves constantly explaining why progress feels slow, why data isn’t ready, why the strategy doesn’t quite answer the questions being asked.
What this looks like: Your strategy covers everything but prioritises nothing. You’re trying to respond to shifting expectations across climate, nature, social, and governance simultaneously — and making limited progress on all of them. There’s no shortage of things to do, but no clarity on what matters most or where to focus first.
Ask yourself: “If your strategy was stress-tested against today’s regulatory and stakeholder expectations, where would the gaps show up?”
Aspiration is table stakes. What separates strategies that deliver:
- It’s structured for topics, not business choices
- Grounded in today’s expectations – not yesterday’s
- Connected to how the business decides – not just what sustainability reports
- Built for delivery – with the capabilities and authority to make it happen
2. It's structured for topics, not business choices
Most sustainability strategies are organised around issues — climate, nature, social, governance. That’s logical: it mirrors reporting frameworks, stakeholder expectations, and how sustainability teams are often structured.
But this creates a gap. Reporting frameworks ask: what are you doing about carbon, water, human rights? Business strategy asks different questions: where should we invest? Which products have a future? What’s our exposure? How do we create value?
A strategy built only around issues answers the first set of questions well. But it doesn’t naturally connect to the second. The sustainability team can describe progress against targets but can’t easily show how sustainability is shaping the choices that drive the business.
The fix isn’t abandoning issue-based structure. It’s building a second view: one that maps sustainability priorities onto business decisions, showing where they intersect with capital allocation, product strategy, market positioning, and operational choices.
Without that translation layer, there’s a strategy for sustainability, but sustainability isn’t in the strategy.
What this looks like: Your sustainability report is comprehensive and well-structured. But when the CFO asks how sustainability affects the five-year investment plan, or when product teams ask which lines to prioritise, the strategy doesn’t have a ready answer.
Ask yourself: “Does your strategy only describe what you’re doing about sustainability issues? Or does it also show how sustainability connects to the business decisions that matter most?”
3. You're making the case in a language the business doesn't speak
The sustainability narrative is often framed around values, commitments, and aspirations. “We’re committed to net zero.” “We believe in responsible business.” “We’re working towards a sustainable future.”
This language resonates with sustainability teams and external stakeholders. But inside the organisation – in the boardroom, in product and market decisions, in supplier negotiations – it lands flat.
These decision-makers respond to risk, return, and resource allocation. They’re asking: What happens to our cost base if we don’t act? Where’s the competitive advantage? What risk are we protecting ourselves against? If we are speaking in vague or far off language, while the business is focused on consequences, then the requirements of sustainability will be overlooked.
But there’s a second translation problem that’s often a crunch point. Even when the C-suite case is clear, the strategy still needs to be translated into the specific language of each function. What does net zero mean for procurement criteria? How does it change buying decisions? What are the implications for product development briefs?
The real work comes in building bridges between enterprise-level outcomes and department-level plans and requirements. Without that translation, the strategy stays abstract – something the sustainability team owns but the rest of the business doesn’t know how to act on.
What this looks like: The board presentation lands well, but nothing changes in how procurement runs its supplier reviews. Business units say they support the strategy but can’t articulate what it means for their priorities.
Ask yourself: “Can every function in your business describe – in their own terms – what the sustainability strategy requires of them?”
4. You have visibility but not influence
Sustainability is visible in most organisations now. There’s a team, perhaps a Chief Sustainability Officer, regular board presentations, maybe a dedicated committee. From the outside, it looks embedded.
But being seen isn’t the same as being heard. And being heard isn’t the same as shaping what happens next.
Influence means having the authority to approve, shape, or block choices that affect sustainability outcomes. It means being in the room when capital allocation is discussed, when supplier selection happens, when product portfolios are reviewed. Being part of operational reviews, not just sustainability updates. Sitting in the meetings where business priorities are set, not just the meetings where sustainability progress is reported.
Most sustainability functions are asked for input but don’t hold authority. They’re consulted – sometimes late, sometimes not at all – but the decisions that determine whether the strategy succeeds get made elsewhere.
The reasons are often structural. Sustainability was introduced in many organisations as a response to external pressure – stakeholder questions, emerging regulation, reputational concerns – and was positioned accordingly.Where the function reports matters: teams that sit within communications, legal, or HR tend to inherit the limited authority of those functions. Teams closer to strategy or finance operate with different leverage.
There’s also a governance dimension. Many organisations have built linear governance for sustainability: teams report up, often all the way to a Responsible Business or Sustainability Committee. But this creates a separate lane.
Sustainability has its own governance – disconnected from, rather than integrated with, the forums where actual business decisions happen. It rarely flows seamlessly and horizontally into business unit leadership teams or executive committees.
Similarly, sustainability risks often sit outside mainstream risk management. They’re tracked separately rather than embedded in enterprise risk management systems or business unit risk processes. And even when sustainability does appear in the risk register, it’s often inadequately referenced and poorly understood. When sustainability isn’t genuinely integrated into how the organisation identifies, assesses, and manages risk, it remains an add-on rather than a core consideration.
Until sustainability has genuine authority – not just visibility – the strategy will remain advisory, and the ability to drive change will be slower going.
What this looks like: You update the board periodically but aren’t part of quarterly business reviews. Significant decisions get made and you learn about them afterwards. The Sustainability Committee meets regularly but has no direct connection to capital allocation or business unit plans.
Ask yourself: “What decisions does your sustainability function have genuine authority over – not input, but authority? And where are the forums where business priorities actually get set?”
5. You have a reporting operating model, not a delivery operating model
Many organisations have built robust infrastructure for sustainability reporting. There are data collection cycles, disclosure timelines, assurance processes, and clear accountabilities for getting the report out the door. The reporting machine works.
But reporting is not delivery. And most organisations haven’t built the operating model for actually executing the strategy.
A delivery operating model answers different questions: Who makes which decisions, and at what level? Where does coordination happen across functions? What are the escalation paths when something is blocked? How do sustainability priorities get embedded into business unit planning cycles? Who is accountable for action, not just for reporting progress?
Without this infrastructure, you have a strategy document but no system to deliver it. Work happens through individual relationships and goodwill rather than through defined processes. Progress depends on who has capacity and enthusiasm rather than on clear accountabilities. Things stall and there’s no mechanism to unblock them.
Consider what happens when a sustainability initiative requires action from procurement, finance, and operations. Without a delivery operating model, there’s no forum where those three functions come together to coordinate. No agreed timeline. No clarity on who owns the outcome versus who contributes.
The sustainability team ends up chasing each function separately, relying on personal relationships to make progress. It works – until someone’s priorities shift, or a key contact moves on, or the initiative reaches an impasse that no one has authority to resolve.
What this looks like: Your reporting cycle runs smoothly but your delivery against strategy targets is inconsistent. When you need something from another function, it depends on relationships not process. Issues get escalated but there’s no clear path to resolution.
Ask yourself: “If you mapped the operating model for reporting and the operating model for delivery, which one actually exists?”
6. The organisation lacks the capabilities the strategy demands
This isn’t about the sustainability team’s expertise. Most sustainability professionals know the frameworks, the science, the regulatory landscape. The question is whether the organisation as a whole has the capabilities to deliver what the strategy requires.
Some of these are systemic. Can the business make decisions under uncertainty, or does it wait for perfect data before acting? Can it work across silos, or do functions protect their territory? Can it hold tension between competing priorities – short-term margin versus long-term resilience – or does one always win by default?
Some are cultural. Is there permission to raise difficult trade-offs, or does the organisation prefer comfortable consensus? Can leaders have honest conversations about where the business model is misaligned with sustainability goals, or are those topics undiscussable?
Some are practical. Does finance have the capability to model sustainability scenarios and integrate them into business cases? Can procurement translate sustainability requirements into supplier criteria and hold vendors accountable? Does product development know how to design for sustainability outcomes, not just compliance?
Sustainability strategies often require capabilities that don’t sit neatly in any one function: translating impact into commercial terms, building coalitions across the business, designing for behaviour change, making decisions without perfect information, managing trade-offs that don’t have clear right answers.
These aren’t technical skills that can be fixed with training. They’re organisational capacities, ways of working, deciding, and collaborating that either exist in the culture or don’t. And if the business hasn’t developed them, the strategy will stall regardless of how good it looks on paper.
The sustainability team can’t compensate for this alone. They can advocate, facilitate, and push but if the organisation around them can’t work with complexity, tolerate ambiguity, or act without complete information, progress will be limited.
What this looks like: Initiatives that require cross-functional collaboration consistently stall. Decisions get deferred waiting for more data. Trade-offs between sustainability and short-term performance always resolve the same way. Functions say they support sustainability but can’t change how they operate.
Ask yourself: “If you were honest about your organisation’s ability to work across silos, make decisions under uncertainty, and hold difficult trade-offs, how would you rate it? And what would need to change for the strategy to be deliverable?”
What now?
- If you recognise your organisation in any of this, the good news is: these are structural problems, not personal ones. They can be diagnosed and addressed.
- You don’t need to fix everything at once. You need to know where to focus. Which of these six is the real blocker? Answer that honestly, and the path forward gets clearer.
- The ground may have shifted and delivery remains complex. The question is whether your strategy – and your ability to deliver it – can respond.
If you need a rapid diagnostic to surface what’s holding you back, the Strategy Sharpener can help.
And if you’re ready for a deeper conversation — whether that’s a full strategy rewrite, strengthening your operating model, or building the internal case for change — we’d be happy to talk.
How to make your annual report work for investors and AI
On 11 February, Luminous hosted a 30-minute webinar featuring Stephen Butler, Reporting Director, and Paris Mudan, Senior Reporting Consultant, exploring how to make annual reports more effective for both investors and AI readers.
About the event
AI is already shaping how investors analyse and compare companies, and corporate reports are a key input. In this practical session, Stephen and Paris shared how reports are being interpreted by AI tools today, what that means for investor decision-making and steps you can take to ensure your reporting performs in an AI-driven environment.
Key takeaways:
How investors are using AI to assess companies and surface insights
What “AI-ready” digital reporting looks like in practice
Practical ways to structure your annual report so it’s readable, searchable, and usable by AI
Insights from a live Q&A with our experts
Resources:
For any follow-up questions or to learn more about our Lumina AI Chat and Review tool, please get in touch with stephen.butler@luminous.co.uk.
Why private equity firms should care about brand
Private equity firms use many strategies to drive value in their portfolio companies. But one they often overlook is brand. It’s a powerful lever, but, if neglected, it could risk leaving money on the table.
Let’s start with the facts first:
- A McKinsey & Company study revealed that brands with strong reputations generate 31% more return to shareholders than the MSCI World average.
- In another study, it finds that fast-growing companies spend more than slower companies on intangible assets such as brand. It concludes that companies that master intangibles investment are well positioned to outperform their peers.
- Strength of brand/marketing is the factor most frequently cited by analysts (79%) when asked how they appraise and analyse companies, compared with leadership quality (76%) and technological innovation (72%).
A strong, consistent brand is one of the most powerful levers for increasing perceived and actual business value. This means that private equity firms should prepare their portfolio companies’ brands with the same attention as their balance sheets.
But, in practice, how can a strong brand help?
By providing clarity: A strong brand helps you be crystal clear on who you are, what you do, who you do it for and why. It helps you reach the customers you chose to serve and helps investors understand your value and the space you occupy in the market.
By creating distinctiveness: A strong brand is distinct and therefore recognisable and memorable. B2B brands especially benefit from having a strong brand as it provides them with a powerful differentiator in the minds of target audiences compared with just talking about features and benefits.
By aligning teams: When your brand isn’t clear and inspiring, every bit of growth demands more effort. When it’s not aligned, it’s like mud, dragging down momentum and slowing progress. But with clarity on your vision and who you are, employees can align, trust is built, decision making can be streamlined and you move faster and smarter.
We have helped several private equity firms rebrand their portfolio companies to set them up for growth. We have brought clarity and focus to seemingly disparate brand portfolios, and we’ve transformed brands from quiet presence to leaders.
Faria – Shaping the future of EdTech
We recently helped Faria Education Group, a global leader in EdTech, to reimagine its brand and create a unified identity across its product portfolio. Through extensive stakeholder consultation and competitor review, we developed a bold, clear positioning: The relentless pursuit of better. The new brand creates standout in a competitive category and pride and belonging internally.
Hubexo – Driving global growth
When Byggfakta Group transitioned from public to private ownership with ambitious growth plans, it needed to unify under one single brand to replace a fragmented portfolio of over 60 regional product brands. We developed a new name (Hubexo), a simplified brand architecture going from 60+ product brands into five core areas, and a new visual identity built around the concept of connection and growth.
Brand is often overlooked as being ‘fluffy’ when in fact it’s the foundation for success. The evidence tells us that, if you’re preparing your business for investment or sale, you can’t afford to ignore your brand.
If your portfolio company’s brand isn’t where it needs to be to ensure future success, then you should take a closer look at it.
Contact us for a 30-minute free consultation.
Sources:
https://www.mckinsey.com/capabilities/tech-and-ai/our-insights/five-fifty-the-invisible-edge
IPA/Brand Finance Investment Analyst Survey
Luminous expands Client Services team with senior hires
We are delighted to announce two key additions to the Luminous Client Services team, as Simon and Lucy join us on our agency’s growth journey.
Lucy Smaill joins Luminous as Client Services Director.
Lucy brings a wealth of experience, having previously led the Client Services team at Given. Her approach is client-centric and people-first, with a strong focus on agile problem solving and long-term partnerships. Lucy has worked with major clients, including John Lewis, Lloyds Banking Group, the National Trust, Kimberly-Clark and Pernod Ricard.
“Stakeholders expect more from communications than ever, and what drew me to Luminous is the way they combine creativity with insight to stay ahead of that challenge. They deliver work that feels both imaginative and grounded in real value, and I’m looking forward to bringing my own focus on people-centric client service into the mix.”
Simon Hutley joins Luminous as Senior Client Director, bringing 19 years of experience at Radley Yeldar. Simon has a proven track record in client leadership, strategic account management, and delivering high-impact projects across multiple sectors, having worked with Barclays, Ferguson, GPE, IHG and Vivo Energy. At Luminous, Simon will play a pivotal role in strengthening client partnerships and guiding strategic delivery.
“I’m thrilled to be joining Luminous, and I look forward to supporting our clients with strategic insight and delivering solutions that make a real difference.”
“Bringing in Simon and Lucy marks an exciting step forward for Luminous. They each bring deep expertise, bold thinking and a shared passion for delivering real impact for our clients. Their experience will help us continue to push boundaries and deliver industry-leading levels of client service and quality.” Justin Boucher, Managing Director, Luminous
For more information, please contact our Senior Marketing Manager, Matilda Paterson.
How brands in workspace and facilities management need to evolve
With technology, sustainability and private equity reshaping workspace and facilities management, brands face a new set of challenges. In our guide, we reveal how to turn them into opportunities.
The UK’s workspace and facilities management industry is going through significant change.
Businesses are increasingly turning to technology solutions, including AI, and data to enhance their facilities management. They are also focused on designing a human-centred workplace experience to create a competitive advantage for talent attraction and retention. And with sustainability high on the agenda, companies are looking to optimise their spaces to reduce their carbon footprint.
Private equity investment is also reshaping the landscape. In 2024, 54% of deals in the sector were backed by private equity, up from 36% in 2022. Investors are starting to see the significant potential in this fragmented market.
These shifts are not only redefining how spaces are managed, but also how brands need to evolve to remain relevant.
Facilities managers play an integral role in supporting an organisation’s goals, such as attracting and retaining talent, and implementing decarbonisation plans. A new type of leader is emerging – one that is digitally fluent, forward-thinking and understands the power of facilities management in achieving business success.
“Workspace and facilities management companies must rethink how to remain relevant and capture the attention of customers. To do so, they will need to re-evaluate their brand and communication.”
That’s where our latest guide comes in.
We outline four strategic imperatives every workspace and facilities management brand should act on now to seize this new era of opportunity.
Download our full guide here
CSRD in flux: From burden to opportunity – or a slow fade?
2025 is proving to be a watershed year for the Corporate Sustainability Reporting Directive (CSRD). Timelines have shifted, the rules are being rewritten, and the tone is changing from rigid prescription to pragmatic proportionality.
There are three big signals from Brussels:
- Stop-the-clock delays – large companies in Wave 2 now start in 2028, with listed SMEs following in 2029.
- Quick fix for early reporters – Wave 1 gets a year’s breathing space on tricky disclosures like anticipated financial effects.
- Two new proposals from EFRAG – simplified SME standards and European Sustainability Reporting Standards (ESRS) 2.0 amendments for everyone else.
Together, they mark a pivot from burden to balance. The question is: can companies use this flexibility to build better sustainability programmes – or will we see ambition quietly shrink?
Full CSRD compliance was always going to be a big ask for SMEs. The new ESRS LSMEs draft offers a lighter, more proportionate path:
- Five core modules: general info, environment, social, governance, business conduct
- Simplified materiality assessment
- Optional extras and phased requirements
- 50% lower estimated cost than full ESRS
It’s open for consultation until November. The final version lands in 2026. It’s voluntary – unless your regulator or your largest customers tell you otherwise.
ESRS 2.0: less grind, more grip
After one year of pain points, EFRAG has listened. ESRS 2.0 pares back the complexity while keeping the rigour. We welcome the intent: moving away from disclosure-as-box-ticking and towards reporting that reflects how businesses actually think about sustainability.
The highlights:
- Top-down materiality – start with what you know matters, skip the exhaustive bottom-up trawl
- Granularity cuts – fewer sub-sub-topics, less repetition
- Executive summary option – lead with your story
- Value chain relief – proxies, sector averages, partial reporting allowed
- Integration freedom – put Policies, Actions and Targets alongside your impacts for a coherent narrative
This is where the stakes rise. Used well, these changes free up resources to focus on strategic sustainability. Used badly, they risk hollowing out reports and making year-on-year comparisons meaningless.
The tension is clear: efficiency vs credibility, pragmatism vs ambition.
What to do now
Whether you were in Wave 1 or years away from mandatory CSRD, now is the moment to:
- test your materiality process against the new top-down approach
- identify where flexibility can add clarity – and where it could damage trust
- decide how to use your executive summary to tell a distinctive, credible sustainability story
- engage in the consultation – shape the rules before they’re locked in.
Our take
EFRAG is signalling that sustainability reporting is growing up. It’s now less about ticking every box. It’s more about telling a focused, authentic story. But freedom demands responsibility.
If you use the space well, you can create reporting that works harder for your stakeholders – and for your business.
If you waste it, you’ll be left with a thinner, less convincing narrative in a market that still demands proof.
For further details, please don’t hesitate to reach out to our Director of Reporting, Stephen Butler.
Introducing Lumina: See your report through AI’s eyes
With AI now the first to read your report, how can you ensure your message, data and context are accurately understood?
It is no longer investors, analysts, stewardship teams or journalists who read your report first: it’s AI.
Reports were once designed for a patient, human reader. Today, they must meet the needs of systems trained to distil signal from noise. Stakeholders will not always read; they’ll query, parse and summarise via AI.
From page to prompt, this shift introduces new risks. Your message risks being:
- missed – crucial points are buried or phrased inconsistently, causing AI to fail in surfacing them;
- misinterpreted – lacking context, AI may extract the wrong meaning;
flattened – nuanced messages are reduced to generic summaries, losing impact.
AI does not reason like the human mind; it retrieves, approximates and stops when it believes it has completed the task. If your data and narrative do not meet its parameters, your compelling story may remain sunken and unseen.
When AI responds, your company’s voice merges with everything else it has absorbed from the web. In these fragmented currents, transparency, consistency and clarity become critical beacons.
A strategic decision
The new reality is that disclosure alone no longer guarantees impact. AI is already analysing your report before it reaches human eyes, determining what gets highlighted and what gets overlooked. This isn’t about rewriting for machines, but about ensuring your story survives translation, thriving in systems that extract, rank and reduce.
The new frontier is about telling the same story, structured to resonate for both human minds and machines.
See your report in a new light – Lumina.
Luminous has developed Lumina, a proprietary simulation tool that reveals how your report is interpreted by AI, before your stakeholders read a word.
By mimicking real-world queries, Lumina analyses how AI models respond to your disclosures. It shows what gets retrieved, what gets skipped and how messages are reshaped or diluted. The tool identifies blind spots, gaps and inconsistencies, allowing you to optimise structure, sharpen messaging and improve impact.
The result? A stronger alignment between what you intend to communicate and what your audiences, human or machine, actually take away.
Built on a unique blend of natural language processing, investor and other stakeholder insights, prompt engineering and corporate reporting expertise, Lumina is specifically designed for the complexity of corporate reporting. It ensures that your message is seen, surfaced and understood. No matter who or what is reading.
If you’re ready to make your next report valuable for both minds and machines, we would love to talk!
Our Resetting Reporting: From Disclosure to Value research calls for a shift from fragmented, compliance-led reporting to value-led, digitally enabled narratives – highlighting how AI is not just a tool, but a new stakeholder shaping how disclosures are read, interpreted and trusted. In the chapter From Tools to Transformation, we explore how reporting can evolve into a more connected, resilient discipline – where AI clarity for both humans and machines is key to standing out.
UK sustainability standards: time to test the waters
As UK SRS moves from voluntary to mandatory, many IROs are asking how to get started. Our Kick Start programme offers a structured pathway to prepare with confidence.
IROs need to ensure that their companies are fully briefed on the new sustainability disclosure standards, which may be voluntary at first, moving to mandatory later.
Three major consultations, launched in June 2025, will form the key components of the government’s programme to make the UK ‘the sustainable finance capital of the world’. At the heart of this intent is the Exposure draft UK Sustainability Reporting Standards UK SRS S1 and UK SRS S2, which is based on the international IFRS standards but has been adapted for a UK context.
The government’s strategic direction is clear: to encourage high-quality, comparable sustainability disclosures that strengthen investor confidence and help support long-term capital flow. While this ambition is bold, a phased approach to adopting these requirements should allow companies to find their footing – making now the right moment to test the waters before the tide of regulation rises. The first phase consists of the following three consultations.
1. Sustainability reporting standards: what’s in scope?
The first government consultation concerns UK SRS S1 and S2. These will mirror the structure of IFRS S1 and S2, which require the disclosure of material sustainability-related risks and opportunities. These disclosures must be made through the company’s annual report, ensuring connectivity with both the financial statements and existing corporate reporting frameworks.
These standards will initially be available for voluntary use, with mandatory adoption likely to be phased in through the Companies Act and FCA listing rules. A regulatory roadmap is promised that will outline the timing, scope and expectations. Six UK-specific amendments are proposed, including:
1. Removing transition relief to prevent compromising the principle of ‘connectivity’ with the financial statements.
2. Extending ‘climate-first’ relief to a two-year period, allowing companies to familiarise themselves before going beyond climate disclosure.
3. Removing mandatory GICS code use to reduce the reporting burden and increase connectivity.
4. Removing fixed ‘effective dates’ to allow regulatory flexibility.
5. Making referencing SASB standards optional, reflecting their lower UK relevance.
6. Clarifying that transition reliefs apply only once mandatory, to avoid penalising early voluntary reporters.
“A phased approach to adopting these requirements should allow companies to find their footing”
These changes aim to balance global consistency with local relevance, without capsizing existing reporting systems.
2. Transition plans: from disclosure to implementation
Alongside the SRS, the government is in consultation about whether large UK companies should be required to publish a 1.5°C-aligned climate transition plan.
The consultations will explore whether transition plans should also cover climate adaptation and biodiversity, and if firms should be held legally accountable for delivery, not just for disclosure.
The third consultation seeks views on whether the Audit, Reporting and Governance Authority (ARGA) should oversee the creation of a new voluntary registration regime for the assurers of sustainability disclosures. The goal is to develop a trusted assurance market, potentially paving the way for mandatory assurance in the future.
CSRD Omnibus update
In April 2025, the EU formally adopted the ‘stop the clock’ proposal, which is part of the EU’s Omnibus package. This proposal gives companies in Waves Two and Three until 2028 to comply with CSRD application requirements.
On June 12th, the European Parliament’s rapporteur presented his draft report on proposed CSRD amendments, reflecting his goal to ‘cut costs for companies and reduce burdens’.
Key changes include:
- Optional climate transition plan reporting. This is required only if a transition plan already exists.
- Trade secrets are generally exempt from sustainability reporting requirements.
- Raising the applicability threshold to 3,000 employees and €450m in net turnover.
- ‘Value chain’ has been replaced by ‘chain of activities’ terminology. Companies may report on a ‘best efforts’ basis when full value-chain information is not available.
The draft will form the basis for the European Parliament’s negotiations towards its final position, which is expected in October, to be followed later by the final policy package.
What IR teams should do now
Although adoption is still voluntary, investor expectations are shifting fast. IR teams shouldn’t delay – they should collaborate early with sustainability colleagues and begin assessing their alignment with UK SRS requirements and the TPT framework to help identify gaps in reporting, build internal readiness and understand where forward-looking disclosures may carry liability risk until safe harbours are in place.
Regarding CSRD, it is worth waiting for updated guidance before conducting a full gap analysis. Companies can still get ahead by starting activities that add value, such as the double materiality assessment, laying important groundwork regardless of the proposed changes and scope.
With over 140 pages of consultation material now available and more to come, one thing’s clear: the tide is turning. Now’s the time to start preparing.
“Companies can still get ahead by starting activities that add value, such as the double materiality assessment”
Find out more about our Kick Start programme and how it can accelerate your UK SRS readiness.
For further details, please don’t hesitate to reach out to our Senior Reporting Consultant, Paris Mudan.
Building a memorable brand: Q&A with Mark Litchfield
At Luminous, we’re known for creating brands that look great, but also work hard and stand the test of time. To unpack what that really means, we sat down with Mark Litchfield, our Executive Creative Director, to talk about what makes a great visual identity, why it matters and how we bring it to life for our clients.
Mark, tell us a bit about your role at Luminous.
“It’s about making sure the creative work we produce aligns with and pushes our clients’ ambitions. It’s not just about making something beautiful; it’s about ensuring every element supports what the brand wants to achieve, while looking for opportunities to go beyond the brief.
Why is visual identity so important for brands, especially in B2B?
“It’s all about instant recognition. A strong visual identity is what stops people scrolling and makes them pay attention. It brings a company’s personality and offer to life, immediately. Think of ‘The Simpsons’: flick through TV channels and you can’t miss them because they look like nothing else. The same idea applies to brands – distinctiveness cuts through.”
Key takeaway: In B2B, where messaging can be complex and competition fierce, a compelling visual identity makes the difference between blending in and standing out. It’s the hook that might get someone to listen to what you have to say.
Can you share some B2B brands you think do this well?
“Consumer brands shook up banking by looking and sounding different – they felt fresh and authentic. In B2B, I think of JTC, one of our clients. Their visual identity genuinely reflects their unique employee-owned model and the creativity they bring to complex portfolio management. It’s distinctive for their sector and connects back to who they really are.”
What makes a visual identity memorable?
It comes down to three big things: authenticity, uniqueness, and consistency.
“Authenticity is key – it comes from looking inward at what your business does well, instead of copying others. Uniqueness naturally follows. And then consistency makes it stick. It’s a simple truth: people inside a business see the brand every day and get bored quickly. But just as they’re tired of it, the outside world is only just starting to notice it. Resist the temptation to tinker too often – consistent application is what builds memorability over time.”
However, consistency doesn’t mean rigidity.
“A brand needs flexibility to adapt to different channels and audiences, but all the pieces should still feel like they belong together. Too strict, and you risk looking repetitive or dated. Too loose, and you lose recognition.”
So how do you develop a visual identity from scratch?
It starts with strategy and understanding where the brand is today and where it wants to go.
“We always balance what’s working now with the ambition for the future. We do a detailed review of what equity the current brand has, whether that’s loyal customer base, recognisable assets, or practical realities like an instantly recognised typeface. We don’t just sweep that away without reason. Then we align that to the new story, positioning and personality the strategy defines.”
Building a brand on these foundations is even more important in an AI landscape. It’s great that companies can now produce things fast. But without a brand strategy or system, it can get messy quickly – inconsistency in visuals and messaging, a disjointed brand experience, all lead to poor engagement.
The bridge between strategy and design is a strong creative idea.
“A good creative idea reveals what a company stands for. It gives people a glimpse of what it’s like to work with that brand – is it playful, bold, reliable? That should come through in every touchpoint.”
Want to know more about our Brand work? Please get in touch.
In the spotlight: Q&A with Ria Jiang
This summer, we have been lucky to have Ria join us on an internship in our Design team. We took the opportunity to sit down with Ria and ask them about their internship experience at Luminous and what inspired them to get into a creative role.
Tell us a little about yourself.
I’m Ria, a design intern at Luminous for three months this summer.
What inspired you to pursue a creative career?
I loved painting when I was very young. I studied at a middle school and high school that focused on art. We spent half the day doing drawing. During that time, I realised I had some talent in design. It’s not just about drawing skills, but about logic, layout, and how everything works together. I feel design is more structured than fine art, and I like that. You need to solve problems, and I enjoy this kind of creative thinking.
Which project at Luminous have you most enjoyed working on or are proud of?
I have worked on three kinds of projects at Luminous. First is the Basic project, which helps train your layout and branding skills. Second is the Fun project, where you can be bold and creative and explore different ideas. The last is the Challenge project, which I enjoy the most. It lets you solve real problems and improve yourself.
For example, I worked on animated icons for rebranding our website. It was my first time doing animation, and it was a big challenge for me. But I felt supported by my lovely design team and they always had my back. That made me feel trusted, and I really wanted to do my best. A few days later, there were more icons waiting for me. This time I saw my own progress very clearly, which made me so surprised and happy.
What’s been the most valuable thing you’ve learned during your time at Luminous?
I think I’ve learned not only about design, but also about teamwork, which is something you can’t learn by yourself.
At Luminous, I’ve worked with many different people. Some are very detail-focused and make everything clear and easy to follow. Others are more relaxed and bring a lot of energy, which makes the work fun.
Also, the way we collaborate makes the whole process very smooth. I did another internship before, and I can say Luminous is really well organised. Even though I’m just an intern, I feel like I can have a chance to understand the whole picture and how things work. That makes my learning more complete and helpful for the future.
What advice would you give to others just starting out in the industry?
Go with the flow!
Before, I studied industrial design, even though I liked graphic design more, so I felt a bit stuck and sad.
If I answered this question as the young me, I would say, “Follow your heart and do what you love.” But now, I think that experience in industrial design helped me learn how to think in a system. That’s also very useful in graphic design and branding, too!
So I would say it’s hard to say what’s good or bad. Even something that doesn’t feel right now can help you later. Just go with the flow!
If you’re keen on becoming part of the Luminous team or wish to learn more about our Creative department, feel free to reach out to us.