CSRD in Action: What Early Reports Reveal About the Future of ESG Disclosure
The Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) are reshaping how companies communicate their sustainability performance. While the EU’s Omnibus package may have pushed back some deadlines, the direction of travel is clear: expectations are rising, and the first wave of reports is already setting the tone for what credible, decision-useful ESG disclosure looks like.
What do early CSRD reports actually look like? We’ve combined insights from EY’s – CSRD Barometer 2025 and KPMG’s Real-Time ESRS Talkbook which analysed the first disclosures.
Length and Structure
Most sustainability statements aligned with CSRD are landing around the 100-page mark — not wildly longer than pre-CSRD reports. This suggests companies are expanding thoughtfully, not just adding volume for the sake of it. On average, firms are reporting against 6–7 of the 10 topical ESRS standards, showing a strategic approach to materiality rather than trying to tick every box.
Our take: Use this first year to build a clear reporting structure. Prioritise what matters most to your stakeholders, and avoid drowning your report in low-value detail.
What Topics Are Getting the Most Attention?
Three standards dominate across nearly all submissions:
E1 – Climate Change
S1 – Own Workforce
G1 – Business Conduct
These areas tend to be the most mature in terms of governance, metrics, and target-setting. Companies are using them to build strong narratives around risk, resilience, and strategic value.
Our take: Don’t just report data — connect it to your business story. Show how climate, workforce, and governance actions drive performance and competitive advantage.
What’s Being Overlooked — and Why That Matters
Some ESRS topics are still underreported:
S3 – Affected Communities
E3 – Water & Marine Resources
E4 – Biodiversity & Ecosystems
For sectors like energy, construction, food, pharma, and chemicals, this is a missed opportunity. These topics are material — and stakeholder pressure is growing.
Our take: Get ahead of the curve. Addressing underreported areas early can help you stand out and build trust before these standards become industry norms.
Material IROs: Quality Over Quantity
Companies are disclosing anywhere from 9 to 130 material Impacts, Risks, and Opportunities (IROs), with most landing between 30–45. There’s a rough ratio of one IRO per three pages of reporting — but volume isn’t the point. The best reports feature IROs that are specific, relevant, and clearly linked to financial and sustainability goals.
Our take: Avoid generic lists. Keep IROs focused and aligned with your strategy. Review them regularly and make sure they reflect what matters most to your business and stakeholders.
Risk vs. Opportunity: A Tilt That Needs Rebalancing
Across the board, companies are reporting far more risks than opportunities. Negative impacts make up around 40% of IROs, while opportunities hover near 10%. This risk-heavy lens can make reports feel defensive — and miss the chance to highlight innovation, efficiency, and growth.
Our take: Reframe your IROs to show how sustainability creates value. Investors and customers want to see how ESG drives innovation, resilience, and long-term performance.
How Are Reports Being Structured?
95% of companies are following the ESRS structure, which supports consistency and auditability.
Most embed the Sustainability Statement before the financial section of the management report.
ESRS-specific labels (like E1, S1, G1) are widely used — helpful for year one, but likely to evolve into more integrated language over time.
Our take: Use the ESRS structure as a backbone for internal alignment. The companies that weave ESG into their core business narrative will stand out.
Assurance: High Effort, Mixed Outcomes
Nearly 90% of early reports received limited assurance, and only 0.5% achieved full reasonable assurance. Assurance often consumes around 20% of the financial audit budget — raising questions about proportionality, especially for first-time reporters.
Our take: Start building assurance-readiness now. Streamline your data systems and documentation early so you can shift more of your ESG budget toward action — not just verification.
Final Thought
CSRD isn’t just a compliance exercise — it’s a reflection of how well your company understands its risks, its opportunities, and its role in shaping a sustainable future. The real question isn’t “Are we compliant?” but “Are we credible?”
Whether you’re preparing your first CSRD report or refining your second, this is your chance to turn ESG reporting into a strategic advantage. Make it count.
