The 2024 financial year marks the beginning of a new era of corporate reporting in Europe. The Corporate Sustainability Reporting Directive (CSRD) obliges numerous companies to disclose their environmental and social impact in a standardized manner – and the first CSRD reports 2024 are now available.
What was previously often considered a voluntary ESG initiative is now a mandatory part of corporate reporting. And: it’s not just a few PDFs. Reporting is carried out in accordance with uniform EU standards (ESRS), is subject to mandatory auditing, is made digitally machine-readable – and increasingly influences investment decisions, rating assessments and regulatory obligations along the supply chain.
New series provides insights
But what do the first 200 or so CSRD Reports 2024 actually say? How successful is the start of the new obligation? Which topics are focused on – and which are conspicuously left out?
In this new series “Inside CSRD”, we analyze in several parts the key findings from a large number of current studies (including those by EY, Deloitte & DRSC, PwC(webcast), Horváth, KPMG, KEY ESG, European Issuers). We not only take a close look at content, but also formats, methodologies, audit processes and industry-specific differences.
Part 1 provides an overview: Who has already reported – and how? What are the dominant sustainability topics? How long and in-depth are the reports really? And what can we learn from the first wave of reports?
The answers provide important orientation for all companies that are still facing their first CSRD reporting obligation – and for all those who want to see CSRD (or VSME) not just as an obligation, but as an opportunity.
2. who reported - and how much?
Although the CSRD does not officially come into force until 2025 (for reports relating to the 2024 financial year), hundreds of companies in the EU and beyond have already published their first CSRD-compliant sustainability reports at an early stage – many of them voluntarily or under pressure from investors, supervisory boards or corporate structures.
Around 200-300 companies made an early move
According to studies by EY, Deloitte, PwC, Horváth and KEY ESG, more than 200 CSRD reports for 2024 were published by March/April 2025 that (fully or almost) comply with the European Sustainability Reporting Standards (ESRS) complied with. EY, for example, analyzed a sample of exactly 200 companies from EU, EEA and selected non-EU countries. Horváth examined 100 reports from 14 countries, while Deloitte focused on 115 German listed companies from the DAX, MDAX and SDAX.
Most of these companies belong to the so-called “wave 1” of CSRD-affected companies – i.e. large capital market-oriented companies with more than 500 employees that were previously already subject to the Non-Financial Reporting Directive (NFRD). Some others (e.g. Swiss groups or US companies with EU subsidiaries) reported voluntarily in order to prepare themselves for regulatory requirements at an early stage or to demonstrate ESG transparency.
Sectors and countries: pioneers with ESG experience
A particularly large number of early reports came from countries with strong capital markets or a pronounced ESG culture:
Germany, France and the Netherlands are strongly represented.
Surprisingly, Denmark and Finland are among the top 5 countries with the most CSRD reports in 2024.
Industry leaders in energy, chemicals, financial services, consumer goods, automotive and tech took the opportunity to position themselves.
Typically, these are companies with existing ESG reporting, internal expertise and/or active investor expectations. However, medium-sized companies and hidden champions are also among the pioneers – particularly in sectors close to regulation.
Early starters - despite legal uncertainty
Interestingly, many of the companies analyzed published their CSRD reports in 2024, even though the national implementation of the CSRD had not yet been completed in their country. At the beginning of 2025, the directive had not yet been formally transposed into national law in more than ten EU countries (including Germany, Belgium and Spain). Nevertheless, companies dared to take the step – a clear sign that CSRD is no longer just seen as a legal obligation, but as a reputational and management issue.
3. scope of reporting: from compact to encyclopedic
How much is “enough” for a CSRD sustainability report? The first round of reports provides a clear answer: the range is huge – from a compact 34 pages to comprehensive reports with over 340 pages.
Average: 100 to 150 pages are the new norm
According to EY, KEY ESG and Horváth, most of the CSRD reports analyzed in 2024 were in the range of 100 to 150 pages. The average value depends on the study:
Ø 123 pages (EY, 200 reports)
Ø 125 pages (Horváth, 100 reports)
Ø 119 pages (KEY ESG, ~40 reports)
One thing is clear: companies that have already reported voluntarily in accordance with GRI or TCFD in the past start with significantly more content – others initially adhere to minimum requirements.
Wide range - depending on industry and reporting maturity
Nevertheless, the range is enormous:
< 50 pages: around 10% of companies, often smaller SDAX companies or companies with selective reporting
50-150 pages: Majority of reports, esp. DAX/MDAX
> 200 pages: around 20 %, mainly from the financial or industrial sector
The following applies: the size alone says nothing about quality or conformity. Some 50-page reports formally fulfilled all ESRS requirements – other 300-page reports shone with a wealth of detail, but a weak structure or a lack of clarity.
Integration in the management report: the new standard
One clear development is the integration of the sustainability report as part of the management report:
71% (according to Deloitte/DRSC) published their sustainability information in an integrated form, i.e. as a separate section in the management report.
Only 28% used a separate sustainability report.
The tendency towards integration is particularly pronounced in DAX companies.
This form of integration strengthens the equivalence of ESG and financial information, as required by the CSRD. At the same time, it facilitates auditing, integration into the annual financial statements and digital processing (keyword: XBRL tagging).
4. top issues: What companies (do not) report
The CSRD obliges companies to make comprehensive disclosures on environmental, social and governance issues – in accordance with the European Sustainability Reporting Standards (ESRS). But what actually ends up in the report? The evaluation of the first reports shows a clear pattern: some topics are almost universally represented – others are surprisingly left out.
The three perennial issues: climate, workforce, governance
Almost all companies report on three standards – regardless of sector or company size:
- E1 Climate change: Is almost universally classified as material. Emissions data, climate targets and initial transition plans are now standard.
- S1 Own workforce: Information on diversity, working conditions and occupational safety is established - also because internal data is usually readily available.
- G1 Corporate behavior: Topics such as corruption prevention, whistleblower systems and ethical behavior are covered almost comprehensively.
These three standards form the core of modern CSRD reports – with high relevance for stakeholders and good access to data within the company.
Weaker representation: External social and environmental issues
Other standards such as biodiversity (E4), supply chains (S2) or consumer concerns (S4) are rated significantly less frequently as material. Reasons for this:
Complexity and data gaps – especially in the supply chain
Less direct relevance in own business model
Phase-in regulations that initially facilitate reporting
Scope 3 emissions are also addressed in many cases, but usually only in part – for example for particularly relevant categories such as “purchased goods & services”.
Climate targets are on the rise
Around three quarters of companies have already formulated a net-zero target, most of them with target years between 2040 and 2050. Transition plans are more common than expected, but there is often room for improvement in terms of content.
5. double materiality - everyone's doing it, but how?
Dual materiality is at the heart of CSRD – and at the same time the biggest challenge for many companies. It requires companies to assess both their impact on the environment and society (impact materiality) and the impact of sustainability issues on the company (financial materiality).
Everyone does it - to different depths
All the companies analyzed carry out a double materiality assessment – because they have to. However, the depth, transparency and methodology vary greatly:
Only around 20% visualize their results in a matrix (Horváth).
Threshold values and justifications often remain opaque.
External stakeholders are rarely systematically involved.
A lot of effort, little standardization
Around 77% of the companies sought external help (EuropeanIssuers) with the double materiality assessment to develop the methodology – mostly on the basis of EFRAG guidance and consulting input.
The number of identified Impacts, Risks & Opportunities (IROs) varies greatly: from 5 to over 100, on average around 40.
6 Putting sustainability to the test: who checks what - and how?
The CSRD puts an end to non-binding ESG statements: In future, sustainability reports must be audited on a mandatory basis – initially with limited assurance, later with reasonable assurance.
Almost all reports have already been reviewed
Although the statutory audit requirement was not yet in force in many countries, over 90% of companies had their reports audited voluntarily – mostly by the existing financial auditor (Deloitte, PwC, EY, KPMG). Most audits were carried out with limited assurance – similar to the previous audit of non-financial statements. Individual companies have already tested Reasonable Assurance, especially for climate data or selected KPIs.
Frequent test notes
Uncertainties in Scope 3 emissions
Methodological questions on materiality assessment
Data quality in the supply chain
Nevertheless, not a single report received a “failure verdict”.
Audit practice is developing. Uniform European standards (e.g. ISSA 5000) are still lacking. The following applies to companies: working with structured data and clear processes at an early stage avoids conflicts later on in the audit.
