As the Corporate Sustainability Reporting Directive (CSRD) begins to take hold, a growing number of companies have released reports for 2024, aligned with the European Sustainability Reporting Standards (ESRS). While many of these first reporters have done so voluntarily — ahead of national transposition deadlines — their disclosures offer valuable benchmarks and directional insights for the next wave of obligated companies.
Drawing on data from PwC’s ‚First CSRD Reporters Study‘, Deloittes ‘Analysis of listed Companies for FY2024’ and the CSRD ES50 analysis by the Sustainability Reporting Navigator, this article outlines four key dimensions of emerging reporting practice: general disclosure patterns, financial risks and opportunities, positive and negative impacts, and how companies are approaching the scope-3 GHG-emissions requirements .
1 General insights from the first CSRD-aligned reports
The early adopters of CSRD reporting have already shown significant diversity in both the breadth and depth of their disclosures:
- Topic Coverage: The most reported topics are E1 – Climate change, S1 – the company’s own workforce, and G1 – business conduct.
- Geographic Leadership: Around 75% of reporters are based in countries that have not yet transposed the CSRD into national law. This means, that despite not being legally required, companies in these countries chose to report—likely seeing sustainability reporting as a tool for better business decisions.
- Disclosure Depth: Some companies report on fewer than 10 topics, others on more than 120
- Value Chain Gaps: Only ~4% of companies provide comprehensive disclosures on value chain impacts.
- Strategic Framing: Many companies use CSRD to reinforce their strategic sustainability narratives.
Compared to previous sustainability reports from 2023:
- the average length grew by 16% in page length, rising from 133 to 154 pages,
- and by 24% in word count — increasing from 72,000 to 89,000 words.
In addition, Sustainability reports are evolving from promotional, PR-style documents into more structured and formal disclosures that increasingly mirror financial reporting. This shift is evident in the growing use of quantitative data, tables, and standardized layouts, accompanied by a noticeable reduction in abstract imagery. These findings demonstrate a broad range of maturity and sophistication in reporting.
2 Financial Risks and Opportunities: Early Signals
One of the defining features of the CSRD is the requirement to report on financially material sustainability topics. Many companies identify more material sustainability-related risks than opportunities, which is understandable given the significant threats posed by climate change and the energy transition. However, it’s notable that firms across various sectors also recognize opportunities for value creation — such as shifts in customer preferences, growing demand for responsible products, and the rise of green technologies.
Further findings from PwC’s study regarding financial risks:
- 84% of companies disclosed at least one financially material impact.
- Climate change is viewed as the leading financial risk across all industries, especially in consumer markets, energy, and industrial sectors (on average 2.6–2.8 risks reported per company).
- Biodiversity and ecosystems, pollution and water risks are underreported in tech and finance, suggesting a gap in recognizing nature-based dependencies.
- Workforce and business conduct rank consistently high, highlighting concerns around social compliance and governance exposure.
- The health industry sees notable risk in consumer and end-user issues (2.3 risks reporte), likely reflecting sector-specific regulatory scrutiny and liability risks.
In this context, it is surprising that several large companies‘ CSRD reports included no mention of any opportunities at all, despite the clear potential for positive strategic transformation in response to sustainability challenges.
3 Disclosed Impacts on people and the environment
Within the second part of the double-material analysis, companies share their views regarding material impacts on people or the environment, considering both their own operations and their wider value chains.
What do they see? Consistent with financial disclosures, companies identify approximately 50% more negative than positive impacts within their sustainability reporting:
- Climate change is viewed as the leading negative impact across all industries, especially in consumer markets, energy, utilities and resources as well as industrial sectors (2.0 –2.8 negative impacts reported on average).
- Workers in the value chain (1.9 – 4.1 negative impacts reported) rank consistently high, highlighting concerns around social compliance exposure.
- Companies in the Energy, utilities and resources industry report a higher number of negative impacts on Biodiversity and Ecosystem than the other analyzed industries (3.5 on average).
Among the limited positive impacts disclosed:
- Companies in the health industry report the highest potential benefits for consumers and end-users (on average 3.9).
- Overall, the most frequently reported positive impacts relate to companies’ own workforce, with average scores ranging from 3.2 in the energy, utilities, and resources sector to 2.3 in financial services.
Ultimately, as with financial opportunities, it remains debatable why most industries report so few positive impacts. That tech, media, and telecom firms disclose none for pollution, water, or biodiversity highlights untapped potential for innovation.
4 Insights on Scope 3 emission reporting
Scope 3 emissions reporting under chapter E1-6 is proving to be one of the most complex yet essential components of climate disclosure. The PwC study reveals that while companies are starting to engage with these indirect emissions, reporting is uneven and often incomplete. Nonetheless, consistent patterns are emerging — especially around which Scope 3 categories are prioritized by industry:
- Selective Disclosure: Companies focus primarily on categories like purchased goods and services (76%-100% of the companies covered) and business travel (>77%), while others (e.g., franchises, use of sold products) are less commonly reported.
- Industry-Specific Patterns: Manufacturing firms report upstream and downstream categories; financial institutions emphasize investments; service sectors highlight business travel.
- Data Limitations Persist: Many firms rely on estimated or secondary data for Scope 3 disclosures, with few achieving coverages based on primary data.
- Use of Phase-In Relief: Many companies apply ESRS phase-in provisions to delay full Scope 3 reporting, especially where data availability is low.
- Materiality-Driven Approach: Disclosures are closely tied to perceived materiality, with firms aligning Scope 3 categories to their business models and value chains.
5 Conclusion
The first year of CSRD-aligned reporting reveals a landscape in transition: from selective storytelling to standardized, regulated, and strategic sustainability disclosure. While many companies struggle with complexity, the leaders are using CSRD to:
- Link ESG to financial risk and business models
- Strengthen their stakeholder communication
- Build internal capacity for data-driven sustainability governance
For companies preparing to report in 2025 or 2026, the message is clear: Start early, focus on materiality, and build your ESG data infrastructure now.
Navigating the complexities of CSRD and ESRS can be challenging—especially when it comes to aligning sustainability strategy with evolving regulatory demands. DFGE – Institute for Energy, Ecology and Economy offers comprehensive support to help companies meet CSRD requirements efficiently and effectively. From conducting double materiality assessments and performing gap analyses to preparing structured, audit-ready disclosures, DFGE provides both strategic guidance and operational support. Leveraging years of experience in sustainability reporting, DFGE enables businesses to transform compliance obligations into value-creating sustainability action. Contact us via mail or phone +49 8192 99733 20.
6 Sources
- Deloitte, Sustainability Reporting Practice under CSRD/ESRS: An Analysis of listed Companies for FY2024
- PwC, What businesses are disclosing under the CSRD
- Sustainability Reporting Navigator, CSRD ES50 Study
