Q1 2025 marked the release of the first wave of sustainability statements prepared under ESRS, coinciding with the European Commission’s release of its first set of Omnibus proposals.
We share our findings and key learnings. These are relevant for all companies looking to improve their sustainability reporting – whether under ESRS, IFRS® Sustainability Disclosure Standards or as part of voluntary reporting.
Fast 50
We analysed the sustainability statements of 50 companies that reported under European Sustainability Reporting Standards (ESRS) in January and February 2025. Our analysis also includes observations from KPMG specialists who are providing ESRS-related advisory and assurance services (referred to as ‘our experience’). Our findings are not necessarily representative, but early-stage reflections based on our experience and the first wave of ESRS reporting.
We will deepen our analysis over time, but even now believe that valuable learnings are emerging that resonate with aspects of the European Commission’s Omnibus proposals.
The Omnibus Proposals
The Commission’s proposals represent a first step towards reducing sustainability reporting requirements in the EU. Striking the right balance between stakeholder needs and the costs to preparers while maintaining the spirit of the EU Green Deal will be a delicate exercise.
Entity-specific matters
The most frequent matters broadly related to:
- Cyber and data security, 31%
- Safety and quality of life, 18%
32
The average number of material impacts, risks and opportunities.
Concentration in five topics
Beyond climate (ESRS E1), most impacts, risks and opportunities related to workforce (ESRS S1 and S2), governance (ESRS G1), and resource use and circular economy (ESRS E5).
A large spread
59%
Over half of material impacts, risks and opportunities were impacts.
