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.
The Frank Bold Society and the Neighbourhood Association Uhelná called on the Czech government today to be more consistent in its negotiations with Poland over mining at the Turów brown coal mine. According to both organisations, the government did not have enough information or time to prepare an agreement that would truly protect Czech interests. Moreover, the government has acted in a non-transparent manner by failing to inform the public in advance of the terms of the agreement being prepared, which should lead to the withdrawal of the action against Poland at the EU Court of Justice. The organisations have therefore drawn up a document with seven basic demands on which the Czech side should insist.
The European Commission recently introduced a draft of the revised EU ETS Directive which, among other things, proposes that 100 % of ETS revenues should be used for environmental measures. We welcome this idea but we’re also sceptical about how the ETS revenues are used in the Czech Republic. Therefore, we have prepared an analysis mapping the use of ETS revenues in Czech Republic and sent it to the European Commission as an input for the recent public consultation. The main conclusions are presented below.
We have analysed hundreds of pages of technical documents and prepared a comprehensive overview of the sustainability reporting requirements under the forthcoming EU legislation. We summarise what ESG data will be critical for companies, banks, and investors in sustainability strategy and management and in the areas of climate change, environment, sustainable activities, employees and supply chains, due diligence, and anti-corruption measures.
