Out of scope, but remain seated in the CSRD train - The journey of the Nederlandse Loterij

Nederlandse Loterij

The Omnibus proposal caused significant uncertainty, especially for companies that might fall outside the revised CSRD-scope. But what do you do when you are already on a moving train? Do you get off, adjust the route, or continue the journey?

For Nederlandse Loterij (Dutch Lotery, or NLO), a state-owned enterprise for which TOSCA managed the CSRD reporting process, these were urgent questions. The organization was already well into implementation when the rules changed. This led to a fundamental reconsideration: if the primary focus is no longer compliance, why continue? And what is the actual value of working according to the ESRS reporting standards under the CSRD framework?

For the management board, there were three decisive reasons to continue. First, the organization’s role as a state-owned enterprise. Transparency towards stakeholders is essential, and CSRD currently provides the most robust framework for this. Second, the organization's scale is more nuanced than it may initially appear. Although NLO fell under the threshold in terms of employee numbers (updated in the Omnibus package), the organization has a substantial financial footprint due to outsourcing, its extensive value chain, high revenues, and its annual contributions to sports, charities, and society. Finally, management recognized that the ESRS standards under CSRD could serve as a management framework that would bring structure and acceleration to the organization’s sustainability approach, while also contributing to its key strategic objectives: Responsible Gaming (offering gambling safely and responsibly) and becoming an Employer of Choice.

What were the benefits?
To be fair, remaining on the CSRD train required significant effort under tight deadlines, with extensive alignment and explanation required across the organization. But ultimately, CSRD proved to be a catalyst for deeper insights, sharper management steering, stronger collaboration, better embedding within the organization, and increased engagement.

Better insight into where improvement is needed
Applying to the ESRS standards under CSRD is a multi-year process. By systematically identifying ESG topics, developing policies, and collecting data, organizations gradually gain better insight. During this first year, the foundation for this was established. Clear KPIs and reporting structures support a more data-driven way of working, where clear definitions and data quality are essential. Quantitative data also helps provide context for qualitative outcomes. For example, measuring employee participation (%) in education or training programs and gender breakdown among senior management positions, NLO gained better insights into the organization's progress and improvement areas. 

More effective management steering on sustainability topics
The ESRS standards contribute to the further professionalization of sustainability management. ESG is increasingly managed in the same way as other strategic topics within the organization. As a result, ESG is evolving into an integrated part of corporate strategy, supported by clear processes, responsibilities, and structural management reporting. For example, the Diversity, Equity & Inclusion policy and environmental policy help NLO make clear choices and develop initiatives that contribute to its objectives. This prevents fragmentation and inefficiency and enables management to steer more effectively and quickly toward measures with the greatest impact.

Multidisciplinary collaboration and organizational embedding
Collaboration across the organization has also evolved. Greater involvement and alignment emerged between teams, and ESG has become increasingly embedded within departments. Some employees took on new responsibilities alongside their existing roles. For example, the procurement department became responsible for environmental topics and collaborated with the marketing department to reduce the environmental impact of campaigns. Strengthening ownership and ensuring proper organizational embedding remain important points of attention. In this way, ESG continues to become more deeply integrated into the organization.

Personal development and engagement
The CSRD journey also had an impact on the individual level. In some cases, the so-called Topic Owners evolved from operational specialists into more strategic business partners. Discussing objectives and policies with colleagues and management made their work more intellectually challenging and meaningful. At the same time, they were given the opportunity to contribute to increasing the societal impact of the organization and the transparency around it.

Conclusion
The experience of working with NLO demonstrates that CSRD is far more than a reporting obligation. Even outside the formal scope, the framework can deliver substantial value. Although it was a challenging journey, remaining on the CSRD train provided NLO with greater insight, structure, and accelerated professionalization. It also supports the organization in steering more effectively toward what truly matters in the future.

In this way, applying the ESRS standards contributes to strengthening stakeholder trust and building a future-fit organization.

Read the 2025 annual report of NLO here.