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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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New reporting rules require certain large EU companies to include in their management report a non-financial statement. These companies need to begin gathering and auditing information in order to be prepared to publish the required information within good time after the end of the 2017 financial year. Frank Bold recently published a short guide on the Non Financial Reporting Directive that identifies who will be affected and explains how to comply with the new reporting requirements.
On September 28, Frank Bold will hold the Creating Sustainable Companies Summit gathering leading thinkers, businesses, policymakers and civil society in Brussels to chart the way to the next generation of corporations and future of corporate governance.
The Brussels office of the public interest law firm Frank Bold is currently recruiting a Legal Research Intern to start immediately full-time, for a period of two months, with the possibility of a four-month extension.
