CSRD Reports 2024: What we can learn from them
The first CSRD reports 2024 are here! We have compiled the most interesting findings from the latest studies here.
- Around 200 to 300 companies published CSRD-compliant sustainability reports for the 2024 financial year, mostly from Wave 1.
- Reports range from 34 to over 340 pages; the average is 100 to 150 pages.
- Climate change (E1), own workforce (S1) and corporate behavior (G1) are the three most commonly reported topics.
- All companies carry out a double materiality assessment, but methodology and depth vary widely.
- Over 90% of companies had their reports audited voluntarily, mostly with limited assurance.
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 for 2024 are now available.
What was previously often a voluntary ESG initiative is now a mandatory part of corporate reporting. Reporting follows 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.
A new series: Inside CSRD
What do the first 200 or so CSRD reports actually say? How successful is the start of the new obligation? Which topics are focused on, and which are conspicuously left out?
In this 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 look closely at content, formats, methodologies, audit processes and industry-specific differences.
Part 1 gives an overview: Who has already reported, and how? What are the dominant sustainability topics? How long and in-depth are the reports? And what can we learn from the first wave?
The findings offer important orientation for all companies still facing their first CSRD reporting obligation, and for those who want to see CSRD (or VSME) as an opportunity rather than a burden.
Who reported, and how much?
Although the CSRD officially applies from 2025 (for reports covering the 2024 financial year), hundreds of companies in the EU and beyond published their first CSRD-compliant sustainability reports early, many of them voluntarily or under pressure from investors, supervisory boards, or corporate structures.
The Omnibus package, in force since 18 March 2026, significantly narrowed the CSRD's scope. The reporting obligation now applies only to companies with more than 1,000 employees AND more than €450m net turnover (both criteria must be met). Many companies that reported voluntarily for 2024 are no longer in scope under these new thresholds.
Around 200 to 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 substantially comply with the European Sustainability Reporting Standards (ESRS). EY 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 "Wave 1" of CSRD-affected companies, i.e. large capital-market-oriented companies with more than 500 employees that were previously subject to the Non-Financial Reporting Directive (NFRD). Some others, such as Swiss groups or US companies with EU subsidiaries, reported voluntarily to prepare early for regulatory requirements 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.
- 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 early.
Typically, these are companies with existing ESG reporting, internal expertise, and active investor expectations. Medium-sized companies and hidden champions are also among the pioneers, particularly in sectors close to regulation.
Early starters despite legal uncertainty
Many of the companies analyzed published their CSRD reports in 2024, even though the national CSRD transposition had not yet been completed in their country. At the start of 2025, the directive had not yet been formally transposed into national law in more than ten EU countries, including Germany, Belgium and Spain. Companies pressed ahead anyway. This is a clear sign that CSRD is seen as a reputational and management issue, not just a legal requirement.
Germany's CSRD transposition law was still pending as of mid-2026, with entry into force expected during 2026.
Scope of reporting: from compact to encyclopedic
How much is "enough" for a CSRD sustainability report? The first round of reports gives a clear answer: the range is enormous, from a compact 34 pages to comprehensive documents with over 340 pages.
Average: 100 to 150 pages are the new norm
According to EY, KEY ESG and Horváth, most 2024 CSRD reports fall in the range of 100 to 150 pages. Average values differ slightly across studies:
| Study | Sample size | Average report length |
|---|---|---|
| EY | 200 reports | 123 pages |
| Horváth | 100 reports | 125 pages |
| KEY ESG | ~40 reports | 119 pages |
Companies that previously reported voluntarily under GRI or TCFD start with significantly more content. Others initially stick to minimum requirements.
Wide range depending on industry and reporting maturity
| Length | Share | Typical profile |
|---|---|---|
| Under 50 pages | ~10% | Smaller SDAX companies or selective reporters |
| 50–150 pages | Majority | DAX/MDAX companies |
| Over 200 pages | ~20% | Financial sector or industrial groups |
Length alone says nothing about quality or conformity. Some 50-page reports formally fulfilled all ESRS requirements. Some 300-page reports had detailed content but weak structure or poor clarity.
Integration in the management report: the new standard
One clear trend is the integration of the sustainability report as part of the management report:
- 71% (Deloitte/DRSC) published sustainability information in integrated form, as a separate section in the management report.
- Only 28% used a standalone sustainability report.
- The trend toward integration is especially pronounced in DAX companies.
This integration strengthens the equivalence of ESG and financial information, as the CSRD requires. It also simplifies auditing, integration into annual financial statements, and digital processing (XBRL tagging).
Top topics: what companies do (and do not) report
The CSRD requires comprehensive disclosures on environmental, social and governance issues in accordance with the ESRS. The evaluation of the first reports shows a clear pattern: some topics appear in almost every report, others are conspicuously absent.
The three perennial topics: climate, workforce, governance
Almost all companies report on three standards, regardless of sector or company size:
- E1 Climate change: Classified as material by almost everyone. Emissions data, climate targets and transition plans are now standard.
- S1 Own workforce: Information on diversity, working conditions and occupational safety is well established, partly because internal data is usually readily available.
- G1 Corporate behavior: Topics such as corruption prevention, whistleblower systems and ethical behavior are covered nearly comprehensively.
These three standards form the core of modern CSRD reports, with high stakeholder relevance and good internal data access.
Weaker representation: external social and environmental topics
Other standards are rated as material far less often:
- Biodiversity (E4): Low reporting frequency, often due to data gaps and complexity.
- Supply chain labor rights (S2): Difficult to cover due to limited supply chain data.
- Consumer concerns (S4): Less direct relevance in many business models.
Scope 3 emissions appear in many reports, but usually only partially, for example covering only "purchased goods and services" as a particularly relevant category.
Climate targets are on the rise
Around three quarters of companies have already formulated a net-zero target, most with target years between 2040 and 2050. Transition plans are more common than expected, but content quality still has room to grow.
Double materiality: everyone's doing it, but how?
Double materiality is at the heart of CSRD and at the same time the biggest challenge for many companies. It requires assessing both the impact on the environment and society (impact materiality) and the impact of sustainability issues on the company (financial materiality).
Everyone does it, but depth varies
All the companies analyzed carry out a double materiality assessment because they have to. However, depth, transparency and methodology differ considerably:
- Only around 20% visualize their results in a matrix (Horváth).
- Threshold values and justifications often remain opaque.
- External stakeholders are rarely involved in a systematic way.
A lot of effort, little standardization
Around 77% of companies sought external help (European Issuers) with the double materiality assessment to develop the methodology, mostly using EFRAG guidance and consulting input.
The number of identified Impacts, Risks and Opportunities (IROs) varies widely: from 5 to over 100, with an average of around 40.
If you are preparing your own double materiality assessment, our Excel template gives you a structured starting point that follows EFRAG guidance and helps you document threshold values clearly.
Sustainability auditing: who checks what, and how?
The CSRD ends non-binding ESG statements. Sustainability reports must now be audited on a mandatory basis, initially with limited assurance and 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 their existing financial auditor (Deloitte, PwC, EY, KPMG). Most audits used limited assurance, in line with the previous approach to non-financial statements. A few companies already tested reasonable assurance, especially for climate data or selected KPIs.
- Uncertainties in Scope 3 emissions
- Methodological questions on materiality assessment
- Data quality in the supply chain
No report received a "failure verdict". Audit practice is still developing, and uniform European standards such as ISSA 5000 are not yet in place. Starting with structured data and clear processes early avoids conflicts later in the audit.
What you can take away from the first wave
The first CSRD reports show that a high-quality CSRD submission is achievable. The pioneers demonstrate what works and where the effort concentrates. The key lessons:
- Start the double materiality assessment early and document your methodology clearly.
- Plan for 100 to 150 pages of content, but focus on quality rather than volume.
- Prioritize E1, S1 and G1 as your core reporting topics, then extend based on your materiality results.
- Build structured data collection processes now; auditors will scrutinize them later.
- Consider integrating the sustainability report into your management report from the start.
Sources
- Sustainability Reporting Navigator
- EY
- Deloitte & DRSC
- PwC(Webcast)
- Horváth
- KPMG
- KEY ESG
- European Issuers
Blog posts on CSRD
Sustainability Scorecard: Your Sustainability Performance at a Glance
Scope 3 and its role in GHG accounting
Competitive advantage through CSRD or just a bureaucratic monster?
Frequently asked questions about CSRD reports 2024
How many companies published CSRD-compliant reports for 2024?
Studies by EY, Deloitte, PwC, Horváth and KEY ESG found more than 200 reports published by March/April 2025 that fully or substantially comply with the ESRS. Most of these were Wave 1 companies previously subject to the NFRD.
How long is a typical CSRD sustainability report?
Most 2024 CSRD reports are 100 to 150 pages long. The range goes from around 34 pages for compact reporters to over 340 pages for large groups. Length does not determine quality or conformity.
Which ESRS topics appear in almost every CSRD report?
Three topics appear in nearly all reports: E1 (climate change), S1 (own workforce) and G1 (corporate behavior). Topics such as biodiversity (E4), supply chain labor rights (S2) and consumer concerns (S4) are rated as material far less frequently.
Do all CSRD reports include a double materiality assessment?
Yes, all companies analyzed performed a double materiality assessment. However, methodology and depth vary widely. Around 77% sought external support, and only about 20% visualized their results in a matrix. Using a structured template helps you document your approach clearly for auditors.
