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We analysed the 2025 reports of 100 large EU companies disclosing sustainability information under the Corporate Sustainability Reporting Directive (CSRD) to assess how companies are addressing critical sustainability challenges in their strategy.
The research evaluated what companies are telling us on climate, double materiality assessment, due diligence, actions and metrics, and governance. After the Omnibus I package narrowed the scope of the CSRD and simplified the standards, the quality of reports now depends more than ever on what companies themselves judge to be material.
The CSRD works as a transparency tool. Users can now distinguish frontrunners from laggards and discern generic claims from actual evidence. However, our research also reveals a very uneven picture when it comes to how companies report on more complex sustainability challenges, as well as a concerning lack of integration in companies’ strategies. Among our key findings:
Our research shows that the CSRD delivers where the standards are clear. Where they require clear metrics and details on ambition and strategy, as with climate transition plans, disclosures are more transparent and useful. Investors, civil society and business partners can distinguish claims from evidence, and frontrunners from laggards, which is vital for sustainable finance. But the same data shows hesitation in the transition, and that is a warning sign for EU competitiveness.
The sustainability transition is also an industrial and innovation challenge. A corporate sector that is not ready for clean industrial policy, green procurement and sustainable finance is a structural risk to EU competitiveness. Uncertainty in transition planning is a warning sign that the CSRD data helps to expose.
Our report goes beyond the findings. It sets out specific conclusions and practical recommendations for companies on how to develop strong reporting practices from climate transition plans and climate risk assessments to double materiality, due diligence and value chain reporting. It also offers directions for public authorities and EU policymakers on how to address the gaps we identified, from assurance and supervision to sector-specific guidance and the wider sustainable finance and industrial policy framework.
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The European Parliament has adopted the Corporate Sustainability Reporting Directive (CSRD), which clarifies transparency obligations for large companies operating in the EU on their sustainability impacts, risks, and opportunities. Pursuant to the CSRD, companies across all sectors will report against the European Sustainability Reporting Standards, which were developed by the European Financial Reporting Advisory Group (EFRAG), submitted to the European Commission and published on 22 November.
NGOs and civil society groups will only support an ambitious first set of sector-agnostic ESRS that closely builds on the EFRAG drafts adopted last November. They urge the Commission to follow EFRAG’s technical advice alongside 60+ companies and investors worth 651bn USD, and caution against making significant changes at this stage, as this would risk discrediting the process so far and undoing a good compromise.
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