
MFT Energy Holding ApS
Annual Report 2025
9
Reporting framework: Adapting to evolving rules
In 2025, our preparations for the Corporate Sustainability Reporting Directive (CSRD) progressed as planned. We
updated our Double Materiality Assessment (DMA), a cornerstone of CSRD, and developed the framework to support
reporting under CSRD. However, 2025 brought significant changes to the sustainability reporting agenda. The European
Commission presented its Omnibus Simplification Package (the “Omnibus”), which initially delayed the CSRD
requirements for wave 2 companies, including MFT Energy, and then reduced the number of companies in scope of
mandatory CSRD reporting going forward. As a result, MFT Energy is no longer within the scope of CSRD reporting. In
addition, the European Commission proposes adopting a voluntary reporting standard as a delegated act for companies
with up to 1,000 employees based on the European Financial Reporting Advisory Group’s (EFRAG) voluntary sustainability
reporting standard for non-listed small and medium enterprises (VSME). Until the delegated act is finalized, the
Commission has issued an intermediary recommendation that companies outside the CSRD scope can use the VSME
standard
Following the Omnibus, we decided to pause the preparations and evaluate alternative reporting frameworks. We
considered several options, including continuing implementation of the full CSRD and both the Basic and Comprehensive
Modules of the VSME standard. The 2025 update of the DMA from 2022 identified fewer material sustainability matters
and generally lower impact, which supports the VSME as a suitable framework for MFT Energy at this stage. As the
voluntary standard is not yet finalized, our sustainability framework this year is inspired by the Basic and Comprehensive
Modules of the VSME standard, while fully meeting the requirements of section 99b of the Danish Financial Statements
Act. Assuming that the regulatory path becomes clearer and the voluntary standard recommended by the Commission is
finalized, we will make the decision in 2026 whether to adopt it partially or fully.
Regardless of where the regulatory path is moving, our commitment to sustainability remains intact. Our sustainability
practices go beyond compliance, and we strive to improve across environmental, social, and governance matters.
Our sustainability framework will therefore continue to center on the three ambitions mentioned previously in this
section. All three focus areas will be elaborated on the following pages.
The responsibility for sustainability is anchored at MFT Energy’s Board of Directors and Executive Leadership.
Environmental
Energy consumption, and hence the energy sector, is a big driver of climate change, but the energy sector is also central
to the solution. According to the International Energy Agency (IEA), the sector accounts for about 75% of global
greenhouse gas (GHG) emissions. Decarbonizing the sector relies on scaling renewable energy sources, such as wind and
solar, and ensuring a flexible energy system to maintain reliability*.
At MFT Energy, we continue to support the green transition by ensuring liquid and efficient energy markets, which enable
the increase in renewable energy sources. Every day, we do numerous cross-border trades. We move energy from regions
with high supply to regions with low supply. The high supply in a certain region can be caused by several factors, but
often, it is driven by overproduction from renewable energy sources. Through trading, we take part in facilitating the
green transition by moving the overproduction of renewable energy to other regions and supporting market liquidity. This
supports the United Nations Sustainable
Development Goal 7, which aims to ensure universal access to affordable, reliable, sustainable, and modern energy, while
significantly increasing the share of renewable energy in the global energy mix.
Greenhouse gas emissions
While the wider energy sector is a major source of global emissions, MFT Energy’s own footprint is relatively small and
predominantly falls within Scope 3, mainly from purchased goods and services and business travel. Consequently, we
have not adopted a standalone climate transition plan for emissions mitigation. However, we are still aware of the