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On May 15, 2025, we hosted a live webinar unveiling the key findings from our latest analysis of CSRD-aligned sustainability reports to shed light on how wave one companies are implementing the Corporate Sustainability Reporting Directive (CSRD), with a look into the topics disclosed and how Impacts, Risks, and Opportunities (IROs) are being contextualized and presented.
The session brought together speakers from EFRAG, Novo Nordisk, and Datamaran’s own team, who, having reviewed our analysis of 300+ CSRD sustainability statements and more than 11,000 IROs (Impacts, Risks, and Opportunities), shared their thoughts on what the findings mean for businesses. This article captures the top takeaways from the webinar, providing insights into the discussion and report findings.
While formatting and structure of reports are beginning to converge, companies are still taking very different approaches in terms of scale and depth. Some companies identified just a handful of material IROs; others listed well over 100.
“The average CSRD statement is 103 pages – virtually the same as pre-CSRD sustainability reports,” said Donato Calace, SVP Market Leader at Datamaran. “That’s an important data point for those concerned about the additional burden.”
On average, companies reported 6 out of the 10 topical ESRS standards as material. This indicates that companies are tailoring their disclosures to what is most relevant; many are not reporting against the full suite of topics – a signal that materiality assessments are being taken seriously, but also that approaches vary significantly across sectors and geographies.
Negative impacts dominate the first round of CSRD disclosures and represent 37% of the IROs analyzed. But to fully meet the spirit of the standards and reflect real-world strategy, companies will need to mature their thinking and reporting on opportunities, which represented only 13%.
“There’s a hesitancy to report on opportunities,” said Samuel Canghiari of Novo Nordisk. “It’s harder to define them, and companies don’t want to promise too much.”
EFRAG’s Gemma Sanchez-Danes added: “We expected this. Due diligence frameworks are built around negative impacts – positive impacts need more definition and guidance.”
Climate Change (E1), Own Workforce (S1), and Business Conduct (G1) appeared in nearly every statement, and were reported by 99%, 98%, and 92% of companies, respectively. Conversely, Biodiversity (E4), Water (E3), and Affected Communities (S3) were the least reported topics, representing 44%, 37%, and 36% of companies signaling potential blind spots.
“Only 44% of companies reported on biodiversity,” said Ian van der Vlugt, VP Market Leader at Datamaran. “This is despite it being the second most severe risk in the World Economic Forum’s global risk report.”
“We know this is an issue of maturity and data availability,” noted Sanchez-Danes. “But companies should anticipate expectations around these topics changing.”
Companies are interpreting materiality in different ways depending on their industry, role in the value chain, and how far ahead they’re looking. This is especially evident in the reporting of standards like S4 (Consumers and End Users) or E4 (Biodiversity and Ecosystems) across sectors, and the distribution of IROs by time horizon.
“We’ve seen that S4 – which we interpret as patient centricity – is clearly material for us,” said Samuel Canghiari of Novo Nordisk. “But we noticed not all peers have taken the same view, which often comes down to how they define their end user and their responsibilities in the value chain.”
Gemma Sanchez-Danes of EFRAG added: “There’s some confusion in how value chain and time horizon lenses are being applied. This is something that will evolve with more guidance and practice.”
Only 14% of the reports analyzed included entity-specific disclosures, despite the ESRS encouraging them when relevant.
Novo Nordisk stood out for including topics such as patient safety and bioethics.
“Yes, they’re voluntary – but they matter,” said Canghiari. “These are topics central to our strategy and stakeholders. They move the conversation beyond compliance.”
Companies in waves two and three have a clear window to learn from peers and enhance their approach.
A key opportunity lies in deepening the connection between IROs and strategic decision-making. By refining the alignment between disclosures and business strategy, companies can move beyond compliance to unlock the full value of CSRD reporting.
“We already do this, but there’s still room to improve how we connect metrics, actions, and governance to material issues,” said Samuel Canghiari.
This evolution should also be supported by improved risk integration. The panelists noted that many sustainability risks, particularly those outside climate or consumer-focused standards, are not yet fully embedded in enterprise risk management frameworks. As materiality assessments mature, the gap between identified negative impacts and recognized risks is expected to narrow.
“This is the first time anyone’s done this,” said Donato Calace. “And it’s already changing how companies think about materiality, governance, and strategy.”
Missed the webinar? You can now watch the full recording on demand and also download the CSRD Reports Uncovered report for all the findings.“The evidence in these reports is essential,” added Sanchez-Danes. “Not just for regulators, but for anyone committed to better, more decision-useful sustainability reporting.”
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