CSRD benchmark 2025: what the first sustainability reports reveal
Published August 4, 2025
- Sustainability
Key takeaways
- Wavestone has analyzed 35 CSRD-compliant sustainability reports from leading European companies across five major industries, looking at both quantitative and qualitative data, thematic maturity, and how sustainability is woven into overall management reports.
- The findings reveal a wide range of approaches and maturity levels, not only across sectors, but also in the shared challenges organizations are facing.
- Below, discover the key insights and hurdles to anticipate as you shape your next CSRD program.
*Corporate Sustainability Reporting Directive
A complex exercise, many projects in motion
Sustainability reports now make up between 20% and 50% of Universal Registration Document (URD) volumes. Behind these publications lies a significant amount of work undertaken by leading companies navigating CSRD requirements in this first year.
Most organizations found themselves launching several internal initiatives simultaneously: raising employee awareness and engagement, aligning efforts between parent companies and subsidiaries, reviewing sustainability policies, improving data reliability, and upgrading reporting tools. It was a demanding process, carried out under often tight deadlines.
This initial round has undeniably helped organizations establish a clear, structured baseline of their most material challenges, as well as a realistic view of the road ahead. However, it has rarely led to a complete rethinking of business models. Still, the groundwork is now laid for driving transformation in the years to come.
Most organizations found themselves launching several internal initiatives simultaneously: raising employee awareness and engagement, aligning efforts between parent companies and subsidiaries, reviewing sustainability policies, improving data reliability, and upgrading reporting tools. It was a demanding process, carried out under often tight deadlines.
ESRS 2: a fresh opportunity to reframe your Sustainability strategy
Even though the directive doesn’t require a specific format, the way information is presented plays a crucial role in making reports clear and offering real insight into how deeply organizations are embracing these new challenges. Most companies follow a hybrid approach: they stick closely to the ESRS 2 outline for general disclosures, environmental topics, and business conduct (G1), while taking a more flexible approach for social standards.
A structured plan, one that mirrors the standards closely, paired with user-friendly graphics, makes these reports easier to understand and compare. Climate-related disclosures (ESRS E1) set a strong precedent: they’re typically more thorough, quantified, and detailed, thanks to years of experience and established carbon frameworks.
As organizations gain experience in other areas, we’ll likely see greater consistency and discipline across the board.
In these first reports, descriptions of the business model mainly serve an informational purpose: a straightforward snapshot of activities, resources, and the value created for stakeholders. What’s often missing is a forward-looking perspective that tracks the momentum and direction of real transformation.
We’re starting to see three clear levels of maturity emerge:
- No business model transformation
Some organizations haven’t yet started to truly transform. They’re just beginning to recognize their impacts and dependencies, but haven’t connected the dots to rethink their business models.
- Sustainable business model by design
Others are ahead, with business models that are sustainable by design—think of sectors like rail transport.
- Highly exposed industries
Then there are those in high-risk industries, such as energy, automotive, or construction. They’ve been working on transformation for years and are better equipped to show how change is unfolding.
Most companies now use a clear, visual summary of their business model often inspired by former non-financial performance reports. But in most cases, this snapshot appears early in the sustainability report, before the real material issues are addressed. Integrating the business model deeper into the report could turn it into a true strategic anchor for sustainability.
The number of IROs (Impacts, Risks, Opportunities) deemed material can range widely—most companies identify between 20 and 80. There’s a strong focus on negative impacts and risks. Opportunities are rarely highlighted. This trend reflects a long-standing risk culture in big organizations, pushing teams to focus on threats in their analysis.
Four ESRS always make the materiality list: E1 (Climate Change), E5 (Circular Economy), S1 (Own Workforce), and S2 (Workers in the Value Chain). On the other hand, topics like Pollution (E2), Water (E3), Biodiversity (E4), and Communities (S3) are less often selected—sometimes for good reasons, but also due to a lack of maturity and measurement.
Few companies have published a visual representation of their double materiality matrix. It’s seen as too sensitive to share publicly.
Key ESRS Topics: what should be on your radar?
Nearly every sustainability report now highlights clear climate goals. Most companies set short-term targets for 2030 and aim for Net Zero by 2050, usually aligned with the 1.5°C pathway and validated by SBTi.
A majority have formalized a climate transition plan. But few fully meet the standards. Financial planning and board-level oversight are often missing.
For climate adaptation, many companies are mapping physical risks to their assets and operations. Far fewer extend this assessment to their full value chain.
Risk analysis for transition is less commonly addressed. When companies do take it on, it often sparks a real shift in their business model. Yet, most of these assessments aren’t tied to clear, funded action plans woven into company strategy.
The EU green taxonomy has helped companies take that first step, identifying aligned CAPEX and starting to direct investments, even if efforts still focus mainly on climate mitigation.
Companies now increasingly recognize E5 as material. Most are further along on managing outputs—like recycling and reuse—than on tracking what comes in. Regulation and strong partnerships with waste management providers help deliver more robust reporting on waste treatment.
Eco-design is fast becoming a strategic priority. It’s seen as a lever for both savings and sustainability. More companies are mapping and optimizing their inbound flows, including raw materials. The goal: a lifecycle approach, not just a tick-box exercise.
Within ESRS S1, topics like working conditions, health and safety, and diversity and inclusion are well covered in most social reports. Human rights policies are gaining ground. The real watchpoints are about scope—think contractors, not just employees—and setting measurable targets.
A key new area is ensuring a living wage for everyone. Most companies say they comply. But they rarely explain how, or define what “living wage” means.
Meanwhile, pay transparency is moving faster—covering gender pay gaps and executive-to-employee ratios. The new Pay Transparency Directive, coming in June 2026, will push this further. Its goal: shrink the wage gap and empower employees with information
Managing risks and impacts for workers across the value chain—and putting responsible sourcing into practice—are still emerging topics in many reports. Sectors like food and textiles are further along, having faced value chain scrutiny earlier and developed better tools.
But for most companies, analysis stops at first-tier suppliers. Many admit they haven’t gone deeper, citing lack of time, resources, or tools. Still, some are setting ambitious goals: mapping more of their value chain and gaining control over the most high-risk links and procurement categories.
This directly echoes the changes brought by the Omnibus package (CSRD, CS3D) as long as we avoid passing reporting burdens down to small and medium suppliers. Let’s focus on impact, not just compliance.
More than compliance: what remains ahead to accelerate your sustainability transformation
CSRD is about more than just making non-financial data comparable. It’s a multi-year program designed to help you achieve your core goals: integrated performance and real business transformation.
Year one of CSRD felt tough—a new, detailed framework can be overwhelming. At the very least, ESRS gave everyone a shared language and logical structure.
CSRD also pushed organizations to step back and agree on the most important sustainability topics, using both impact and financial materiality perspectives. Many used CSRD as a springboard to bring together CSR, Finance, and Risk teams. It’s a way to make business units accountable, professionalize extra-financial reporting, and measure how far you’ve come and how much work remains.
Key action points include:
- Clarifying resources for transition plans and building clear climate adaptation roadmaps
- Structuring how you manage and preserve natural resources—water, pollution, biodiversity, and circular economy
- Broadening your value chain focus, connecting with due diligence, and improving responsible sourcing criteria and levers
- Aligning and operationalizing HR policies so they cover every entity and group, with measurable, tracked targets and outcomes
Feedback on CSRD program duration and sizing
Varying timelines and team sizes for CSRD programs are shaped by four key factors:
- Group and subsidiary coordination
- Change management and employee engagement
- Policy reviews and project depth
- Reporting tool upgrades
Beyond these, project complexity, the standard’s detail, auditor expectations, and overall workload are often underestimated.
In short, most projects take at least 12 months. On average, CSRD programs last 15 months, with a typical staffing load of 6.9 FTEs (median 5.5 FTEs).
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15 months, it is the average duration of CSRD programs
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6,9 FTE, it is the average size of the core team of CSRD programs
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How should you structure your CSRD approach? What is the impact of the Omnibus Law? How long does it take and how should the team be sized? Our team of experts is available for a personalized presentation of this benchmark, to share our feedback and provide insights for your upcoming CSRD program.