Skip to main content

      With the first wave of CSRD (Corporate Sustainability Reporting Directive) reporting behind us, many companies, are already preparing for the next. This includes both first time reporters and those entering their second cycle, While the regulatory landscape continues to evolve, particularly with the Omnibus Directive, reporting obligations for wave one companies remain in place. For those in wave two and beyond, the experiences of early reporters offer valuable insights into what to prioritize and where to focus.

      The following five “no-regret moves” are based on common challenges and effective practices observed during the first reporting cycle. They represent practical steps that can help streamline the process, reduce risk, and enhance the quality of sustainability disclosures.

      Christian Møllegaard

      Partner, Audit

      KPMG in Denmark


      Katrine Geipel
      Katrine Geipel

      Manager, Audit

      KPMG in Denmark


      Learning 1 - Adjust the timeline: Start preparing in time
      Adjust the timeline: Start preparing in time


      One of the most common bottlenecks in the first reporting round was the late completion of narrative sections.

      This led to rushed reviews, inconsistencies, and limited time for assurance, ultimately compromising report quality.

      Recommendation: Start drafting narrative disclosures early to allow sufficient time for alignment, review, and refinement across teams.

      Learning 2 - Strengthen processes, controls and enablement
      Strengthen processes, controls and enablement

      Many companies lacked clear responsibilities, structured workflows, and internal controls. Much of the work remains manual, with limited use of enabling software.

      These gaps caused delays, last-minute corrections, and assurance challenges, increasing the risk of errors and inefficiencies.

      Recommendation: Define roles and responsibilities, implement structured review processes, and strengthen internal controls. Invest in technology solutions to support more efficient workflows and reduce manual processes.

      Learning 3 - Improve disclosure quality and credibility
      Improve disclosure quality and credibility

      We noted that disclosures sometimes lacked clarity, consistency, and sufficient detail during the assurance process. Definitions and data sources were unclear, and the tone varied across sections in the report.

      This led to restatements of comparative quantitative figures and increased the assurance burden. It also made the report harder for stakeholders to understand.

      Recommendation: : Strengthen data governance and validation by establishing robust processes and controls to ensure reliable data that supports management decisions and reporting. Write the report clearly, at the right level of detail, and ensure it is well structured, and consistent in tone. Refer to insights from our Fast50 report for further recommendations.

      Learning 4 - Get Senior Leaders involved
      Get Senior Leaders involved

      Limited engagement from senior leadership weakened internal alignment and strategic integration.


      This caused sustainability reporting risks to become siloed and disconnected from core business priorities.

      Recommendation: Engage senior leaders early to elevate the importance of CSRD, drive cross-functional collaboration, and embed sustainability into strategic decision-making.

      Learning 5 - Think beyond compliance: Focus on impact
      Think beyond compliance: Focus on impact

      In their first year of CSRD reporting, many companies focused on achieving compliance - overlooking its potential to communicate real impact. For example, many disclosed net-zero targets as part of their transition plan but did not fully disclose current or future investments to support that transition. This may undermine the credibility of their plans, reduce the strategic value of reporting, and limit opportunities to build trust.

      Recommendation: Reassess what is truly material and focus on areas where the company can make a real impact. Use CSRD as a strategic communication tool. Refer to insights from our AI screening publication to identify opportunities to beyond compliance and demonstrate meaningful progress.

      Learning 1 - Adjust the timeline: Start preparing in time

      Adjust the timeline: Start preparing in time


      One of the most common bottlenecks in the first reporting round was the late completion of narrative sections.

      This led to rushed reviews, inconsistencies, and limited time for assurance, ultimately compromising report quality.

      Recommendation: Start drafting narrative disclosures early to allow sufficient time for alignment, review, and refinement across teams.

      Learning 2 - Strengthen processes, controls and enablement

      Strengthen processes, controls and enablement

      Many companies lacked clear responsibilities, structured workflows, and internal controls. Much of the work remains manual, with limited use of enabling software.

      These gaps caused delays, last-minute corrections, and assurance challenges, increasing the risk of errors and inefficiencies.

      Recommendation: Define roles and responsibilities, implement structured review processes, and strengthen internal controls. Invest in technology solutions to support more efficient workflows and reduce manual processes.

      Learning 3 - Improve disclosure quality and credibility

      Improve disclosure quality and credibility

      We noted that disclosures sometimes lacked clarity, consistency, and sufficient detail during the assurance process. Definitions and data sources were unclear, and the tone varied across sections in the report.

      This led to restatements of comparative quantitative figures and increased the assurance burden. It also made the report harder for stakeholders to understand.

      Recommendation: : Strengthen data governance and validation by establishing robust processes and controls to ensure reliable data that supports management decisions and reporting. Write the report clearly, at the right level of detail, and ensure it is well structured, and consistent in tone. Refer to insights from our Fast50 report for further recommendations.

      Learning 4 - Get Senior Leaders involved

      Get Senior Leaders involved

      Limited engagement from senior leadership weakened internal alignment and strategic integration.


      This caused sustainability reporting risks to become siloed and disconnected from core business priorities.

      Recommendation: Engage senior leaders early to elevate the importance of CSRD, drive cross-functional collaboration, and embed sustainability into strategic decision-making.

      Learning 5 - Think beyond compliance: Focus on impact

      Think beyond compliance: Focus on impact

      In their first year of CSRD reporting, many companies focused on achieving compliance - overlooking its potential to communicate real impact. For example, many disclosed net-zero targets as part of their transition plan but did not fully disclose current or future investments to support that transition. This may undermine the credibility of their plans, reduce the strategic value of reporting, and limit opportunities to build trust.

      Recommendation: Reassess what is truly material and focus on areas where the company can make a real impact. Use CSRD as a strategic communication tool. Refer to insights from our AI screening publication to identify opportunities to beyond compliance and demonstrate meaningful progress.


      Looking ahead

      The first round of CSRD reporting has shown the importance of early planning, strong governance, and a strategic mindset. These no-regret moves can help organizations meet regulatory expectations and strengthen their sustainability positioning in a rapidly evolving landscape. We can help you navigate the regulation and support your CSRD journey. 


      Other relevant services and insights

      We help you make sustainability an integral part of your business and guide you safely through the requirements.

      We help you get an overview of requirements and data, ensure good processes and explore business opportunities along the way.

      The massive ESG reporting wave sweeping Europe: Danish companies are ahead, but full disclosure remains a challenge.

      Contact us

      Please reach out if you would like to hear more about how we can help you with ESG reporting.

      Christian Møllegaard

      Partner, Audit

      KPMG in Denmark

      Katrine Geipel
      Katrine Geipel

      Manager, Audit

      KPMG in Denmark


      Subscribe to our KPMG insights newsletter



      Turn insight into opportunity with unique perspectives and actionable insights addressing the burning issues atop the C-suite agenda. We cover everything from ESG and new technologies to transactions and financial services.