With the final revision of the CSRD landing only in mid-December, many companies spent 2025 navigating a moving goal post. Yet despite the uncertainty, some clear lessons have emerged from those already reporting under the new rules. So what did companies actually struggle with, and what did they take away from the experience?
Legislation on sustainability reporting itself isn’t new. What is new, is the application application of a common and more comparable European standard with defined metrics. This shift required many teams to streamline internal data processes, upgrade skills, and strengthen links across departments.
In other words, CSRD wasn’t just another compliance exercise; it marked a significant adjustment period. Below are key insights and takeaways from companies’ first-year reporting experience.
The EU’s “stop-the-clock” CSRD delay and the introduction of new thresholds in late 2025 created considerable uncertainty. For many companies weighing whether to dedicate resources to CSRD reporting, it remained unclear until late 2025 whether they would ultimately remain in scope or be able to delay reporting until the following year. This concern was not unfounded, given that around 90% of companies were removed from scope under the final draft of the CSRD.
Even seasoned reporters had to familiarise themselves with the new standards. Establishing new processes inevitably takes time and resources, and the adjustment to CSRD was no exception. That said, many companies already had sustainability reporting teams in place, which provided a solid starting point.
Ørsted’s Head of ESG Accounting, Niels Strange Peulicke‑Anderson noted that CSRD ”has been super, super helpful for the internal alignment and agreement of what is really material for Orsted". This illustrates both the initial adjustment required and the tangible benefits that can result from the process.
CSRD reporting is anything but a siloed task. Companies quickly learned that it touches finance, legal, HR, procurement, operations, to name but a few areas. Coordinating across departments was one of the biggest hurdles, especially in the absence of a central project owner, often requiring external support.
The traceability and granularity required by ESRS pushed many companies to rethink their data systems. Several had to introduce new collection methods or invest in tools simply to keep up. Manual spreadsheets were...not enough.
The double materiality assessment (DMA) proved to be the intellectual backbone of the processand one of its most challenging elements. Companies found the assessment worked best when tailored to their specific business model, sector, and risk profile, rather than relying on one-size-fits-all templates.
Success often stemmed from a thorough screening of the company’s business model and value chain, helping to build a clearer understanding of impacts, risks, and opportunities. Importantly, the assessment was not about judging current sustainability performance, but about working from existing capacities with a view to progressive, future improvement.
Some companies had already completed gap analyses and early scoping work, which boosted their confidence. Others were still laying the groundwork when the reporting season arrived. Preparedness varied widely, effectively dividing companies into those that reacted to the new requirements and those that had proactively anticipated them through early, company-wide engagement.
Some companies began to rethink CSRD altogether. Rather than treating reporting as an end in itself, they discovered that the real value lay in the double materiality assessment. Identifying risks and impacts provided the foundation for more meaningful reporting, helped companies look beyond quarterly planning horizons, anticipate future challenges and opportunities, and support more resilient long-term decision-making.
The earlier you begin planning and gathering data, the smoother the process will be.
Treat reporting as a company-wide exercise, not a sustainability side project.
There’s no need to start from scratch. Build on existing know-how, functions, and resources to jumpstart the process.
A robust double materiality assessment depends on solid input from across the organisation and relevant external actors.
Digital tools help streamline data flows, reduce errors, and support traceability requirements.
From finance to sustainability specialists, people need the skills to understand and apply the new framework.
CSRD is not a one-off project. Companies that adopt a mindset of continuous improvement and transparency gain the most strategic value in the long run.
If 2025 was about learning to walk under CSRD, 2026 will be about learning to run. As 2026 progresses, Frank Bold will bring you more useful resources to navigate the ins and outs of CSRD and CSDDD, including regular updates through newsletters, webinars, podcasts and our best practice database that is currently under development.
In the meantime, you can explore our recent report on the CSRD reporting performance of 100 companies.
In the context of the last phase of the negotiations on the Corporate Sustainability Due Diligence Directive (CSDDD), Frank Bold initiated a multistakeholder statement together with the Responsible Business Alliance (RBA) and Shift.
Today, the European Parliament successfully fended off efforts to reject the European Sustainability Reporting Standards (ESRS), a key legislative piece to ensure the effective application of the Corporate Sustainability Reporting Directive (CSRD) and the transitioning efforts in the context of the Green Deal. A majority of 359 Members of the Parliament voted against a motion to reject the ESRS and its replacement with an emptied and diluted piece of legislation.
In light of today’s State of the Union Address by President von der Leyen and the ‘SME relief package’ presented by the European Commission yesterday, Frank Bold calls on the Commission not to disregard the political agreement reached in 2022 on the Corporate Sustainability Reporting Directive (CSRD).
