The Omnibus package of proposals will simplify sustainability reporting for many organisations, but what learnings can we take from the Wave 1 CSRD reporters?
Whilst the CSRD Omnibus proposal is in progress, KPMG looked at the Corporate Sustainability Reporting Directive (CSRD) reporting by 50 companies that issued in January and February 2025.
Our early-stage findings show trends that are relevant for all companies who will be reporting on sustainability performance, whether for regulatory purposes, or to meet wider stakeholder demands.
Our Fast 50 key findings
- A wide range exists in the number of material impacts, risks and opportunities (IROs) identified in the double materiality assessment (DMA), ranging from 9 to 93 material IROs, with an average of 32.
- Out of all IROs identified, most link to S1 Own Workforce, E1 Climate Change and G1 Governance, followed by E5 Resource Use & Circular Economy, S2 Workers in the Value Chain and S4 Consumers and End-users (in order of magnitude).
- 59% of material IROs were impacts, that were dominated by negative impacts (two-thirds). Out of all material IROs, risks and opportunities count for 29% and 12% respectively.
- Half of all impacts identified materialise within own operations, with the other half almost equally distributed across the upstream and downstream value chain.
- First wave reporters had relatively mature climate-related disclosures, with 62% including a net-zero target/commitment (by 2050) and 86% including information about climate scenario analysis.
- Disclosing metrics on material IROs did bring challenges in relation to data quality that had to be resolved with significant sources of judgement noted across reporters.
- The link between sustainability performance and how it informs a company’s business strategy was unclear.
- Overall, the planned reduction of ESRS is welcomed to enable reporters to effectively communicate on their business and sustainability strategy.
What to do next
As you think about next steps on your sustainability reporting journey, whether that be for CSRD ESRS reporting or indeed other drivers, some of the key learnings that can be taken forward include:
- Execute or refine your DMA process – If not already undertaken, a DMA will help to set the direction of your future ESG reporting. Look for opportunities to further refine your DMA process and IROs, and consider the critical link material IROs will have on your company strategy.
- Step back from the data – Determine the most effective structure for your Sustainability Statements (or Sustainability Report), and look for opportunities to better reflect the story the data is telling and how it informs the business strategy, rather than a compliance statement.
- Continue momentum on sustainability – With a greater focus on climate reporting observed, getting the basics right on areas such as scope 3 GHG emissions, climate scenario analysis and net zero transition plans, continue to be business imperatives.
Real-time ESRS: Fast 50
Read in full the findings and key learnings from our Real-time ESRS: Fast 50 report which details the experience of first wave reporters.
*The early-stage findings are based on 50 companies headquartered in the European Economic Area. The sample comprised a wide variety of sectors with no individual sector representing more than 18% of the population. The analysis is not necessarily representative, but early-stage reflections based on the first wave of ESRS reporting complemented by experience of KPMG specialists providing ESRS-related advisory and assurance services.
Get in touch
ESG reporting is an increasingly complex challenge for business. Regulations governing ESG reporting (e.g. CSRD) globally are in flux, yet the expectations from banks, investors, customers and other stakeholders, is that companies are clear in their understanding of impacts on people and the environment, as well as the risks and opportunities that ESG factors can have on business. The management, mitigation and reduction of ESG related impacts is a business imperative. Leveraging our expertise, we can help your business to:
- Understand your ESG reporting obligations globally
- Assess your material impacts, risks and opportunities through a double materiality assessment
- Determine the availability and quality of your ESG data to meet stakeholder expectations
- Assess your climate change related risks, scenario analysis and assist in the development of your transition plan
- Develop/revise your sustainability strategy
- Develop a target operating model for sustainability performance management
- Establish governance mechanisms, processes and controls relating to ESG performance data
- Implement technology solutions to support ESG data management
- Prepare for limited assurance through assurance readiness procedures
- Report on your ESG performance in a Sustainability Report, Annual Report or Sustainability Statement.
Contact our team today to explore how you can prepare your business for ESG reporting.
