CSRD Reports in Practice: What Recent Studies Show

Two full reporting seasons based on the European Sustainability Reporting Standards (ESRS) are now available. Anyone preparing their first report today is therefore no longer reliant on individual voluntary pioneer reports. Several analyses have systematically examined hundreds of published reports, revealing how long these reports are, how many topics are considered material, and where quality issues typically arise. Read this article to learn what you can adopt from these findings and what you should not apply directly due to the revised ESRS.

What obligations the CSRD imposes and who it still applies to under the Omnibus Package

The Corporate Sustainability Reporting Directive (CSRD) requires companies to report on their sustainability performance in a standardized manner. It mandates disclosures on environmental, social, and governance (ESG) factors, is based on the ESRS, and relies on a two-part materiality analysis that determines which issues are relevant to a company.

The scope of application has changed fundamentally as a result of the Omnibus Package. The Omnibus I Directive (EU) 2026/470 was published in the Official Journal of the EU on February 26, 2026, and entered into force in mid-March 2026. Since then, only companies with more than 1,000 employees and net revenue exceeding €450 million are subject to reporting requirements. Being capital market-oriented alone no longer triggers a reporting obligation. Member States must transpose the changes into national law by March 19, 2027; the requirement applies to fiscal years beginning on or after January 1, 2027, meaning the financial statements must be published in 2028. As of the latest update, the German implementation was still pending. Read more in our article on the CSRD Implementation Act.

The Data Set: Four Analyses from Two Reporting Seasons

Instead of individual sample reports, we now have a wide range of samples available. Four analyses are particularly useful for preparation:

• EFRAG, “State of Play 2026,” published on July 1, 2026. The analysis examines 905 audited sustainability statements for the 2025 fiscal year, making it the most recent and largest sample to date.
• EFRAG, “State of Play 2025,” published in July 2025. The previous edition analyzes 656 sustainability statements for fiscal year 2024 and allows for a comparison between the first and second reporting periods.
• DRSC and Deloitte, published in November 2025. The study , “The Practice of Sustainability Reporting under CSRD/ESRS,” analyzes 77 reports from German DAX, MDAX, and SDAX companies for the 2024 fiscal year and examines the disclosures down to the individual requirements.
• WWF, published in September 2025. The analysis of 64 reports from DAX 40 and ATX Prime companies for the 2024 fiscal year evaluates the quality of the content much more strictly than the other evaluations.

Classification: All reports examined comply with ESRS Set 1 dated July 31, 2023. On July 3, 2026, the European Commission adopted a revised version of the ESRS as a delegated act. The revised standards are mandatory for fiscal years beginning on or after January 1, 2027; early adoption is permitted on a voluntary basis for the 2026 fiscal year. The number of mandatory data points has decreased by approximately 60 percent, the total number by over 70 percent, and the standard text has been reduced from 284 to 185 pages. The structure and approach of these reports remain instructive; however, their length is no longer a benchmark.

What the analyzed reports on scope and structure reveal

• The length is already decreasing. For fiscal year 2024, the average was 115 pages, the median was 100 pages, and the range was from about 25 to 440 pages. For fiscal year 2025, the average dropped to 95 pages. The sustainability statement thus accounts for about one-third of the entire annual report. German index-listed companies are significantly above this: According to the DRSC study, the average is 130 pages, and for DAX companies, 157 pages. With the reduction in data points under the revised ESRS, the length is likely to decrease further.
• Six to seven material topics are the norm. On average, companies classify 6.4 of the ten topic-based ESRS as material. Only about 10% report on all topics, while about 25% report on four or fewer. Three topics are virtually always included: climate change (99%), the company’s own workforce (99%), and corporate policy (95%). Companies whose own materiality analysis falls significantly outside this range should document their reasoning particularly carefully.
• About 40 IROs per report, with a wide range. German index companies report an average of 43 impacts, risks, and opportunities (IROs): 16 negative and 12 positive impacts, 10 risks, and 5 opportunities. The range extends from 6 to 118. This number is not a measure of quality, but it serves as a useful benchmark for assessing the plausibility of one’s own analysis.
• The prescribed structure is not sufficient for most sustainability reports, which should be organized into four sections: general information, and environmental, social, and governance information. 74% of the German reports examined use additional sections, and 77% place the IRO overview in accordance with ESRS 2 IRO-2 in a separate section. The revised ESRS will explicitly allow for alternative structures in the future. Nevertheless, adhering to the standard structure remains the safest choice for comparability.
• The dual materiality analysis is updated, not repeated. 82% of companies have updated their materiality analysis for the 2025 fiscal year compared to the previous year, and 67% use a hybrid approach combining top-down and bottom-up elements. The revised ESRS also call for precisely this top-down approach. Anyone setting up the analysis from scratch now should design it as a process that can be updated over time from the very beginning.
• Audits with limited assurance are the norm: 73% of the German reports examined were audited with limited assurance, and 20% were additionally audited in specific areas. All resulted in unqualified opinions. For your own planning, this means that the auditability of the data source is what matters, not the linguistic formulation.
• The design becomes more understated. Since the explanation is included in the management report, the brochure-like style of earlier voluntary reports takes a back seat. Charts and tables remain useful for visualization, while images that do not convey meaningful information can be omitted. Notably, only 6% of the reports include their own summary. Those who include one stand out with minimal effort.

Where the First Mandatory Reports Fall Short

The analyses reveal not only patterns but also recurring gaps. These are the real benefit for anyone who will be reporting on this later.

Targets are missing for half of the key issues. On average, companies identify 6.4 material topics but set measurable goals for only 3.3 of them. This discrepancy is immediately apparent to auditors and readers.

IROs remain vague. In the WWF analysis, only 26 of 64 reports linked their IROs to specific business activities; 17 reports lacked time horizons; and only 36 distinguished between potential and actual impacts. A structured overview of IROs in the form of a table at the beginning of each thematic chapter—including the stage of the value chain, time horizon, and type of impact—addresses these three issues at once.

Actions are reported as effects. Occupational safety training is not a positive outcome, but rather a measure to mitigate a negative one. This confusion runs through both reporting periods and complicates the review.

The value chain remains unclear. Only 28 of 64 reports provided a transparent description of their value chain; fewer than half supported their impact assessments with quantitative data. 41 of 64 took advantage of phase-in provisions.

Transition plans and incentive systems are lagging behind. Depending on the analysis, 55% to 69% disclose a climate transition plan, and 63% link sustainability performance to executive compensation. Both of these are indicators of whether the materiality analysis has actually influenced corporate governance.

What You Can Take Away From This for Your First Report

These reports are intended as a guide, not as a template for the scope of disclosure. We recommend adopting the structure, the IRO presentation, and the logic of the materiality analysis. Expect the scope to be significantly smaller, as the revised ESRS will apply starting with the 2027 fiscal year, rather than the 2023 set on which these reports are based. And focus your preparations on the areas where the published reports are lacking: measurable goals for each material topic, IROs relevant to business operations and the time horizon, and a substantiated description of the value chain.

Use Current Reports for Guidance with CONSUST

Preparing a sustainability report in accordance with the CSRD still involves a significant amount of work, even though the revised ESRS reduce this burden. Using published reports as a guide makes the process easier. We have integrated practical insights and examples into our FramesCube CSRD/ESRS software and support you with dual materiality analysis, data collection across all companies, and AI-powered reporting.

Our comprehensive list of ESRS sustainability aspects highlights the topics that may be relevant in this context. You can find the complete roadmap leading up to the first report in 2028 in our white paper , “Implementing CSRD with Confidence: Four Phases to the First Report for 2027.” Contact us for a no-obligation consultation on how to streamline your CSRD process.