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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.
Explore the research
Frank Bold has recently become a certified B Corporation for its activities as a law firm. This new status reflects the firm’s general policy of combining its business activities with socially valuable objectives.
To support our advocacy work on concrete legislative proposals and recommendations, we collaborate with partners from the Czech Republic, Poland, and Slovakia to prepare and publish reports, case studies, data analyses, and examples of international best practices.
To start the New Year with an interesting and thought-provoking event, Frank Bold and ClientEarth organised a screening of This Changes Everything, a documentary based on Naomi Klein’s international non-fiction bestseller.
