What EFRAG’s analysis of 656 CSRD reports tells us about the state of corporate sustainability

EFRAG’s ‘State of Play’ report, which gathers insights from 656 CSRD-aligned sustainability statements, shows wide variations in corporate sustainability ambition and strategies.

EFRAG – the organisation behind the European Sustainability Reporting Standards (ESRS) used for reporting under the Corporate Sustainability Reporting Directive (CSRD) – has published its first large-scale analysis of information disclosed by 656 companies for the 2024 period.

Materiality assessments: Workforce and climate change in the top spots

It reveals that the most sustainability materials topics for companies in the EU are climate change (with 98% of firms identifying it as material), own workforce (99%), business conduct (93%), consumers and end-users (68%), circular economy (65%) and workers in the value chain (63%). These six topics are deemed material by at least 60% of companies within CSRD’s scope.

Only 10% of EU firms identified all 10 of the ESRS topical standards as material, while around 25% selected four or fewer topics as material. At the same time, all topics are considered material at least to some extent: none of the topical standards were considered material by fewer than 30% of firms.

But the analysis also reveals the sub-topics are rarely considered material for companies, with fewer than 5% reporting on pollution of living organisms and food resources, microplastics,  communities’ civil and political rights, rights of indigenous peoples, as well as biodiversity and animal welfare.

More than half of firms have a climate transition plan

Looking specifically at environmental disclosures, the data analysed by EFRAG shows that only 20% of companies reporting under CSRD currently use an internal carbon pricing mechanism. Most of the ones that do are in the mining, electricity and transport sectors.

And despite progress in standardising biodiversity impact assessment, only around 30% of companies across all sectors reported biodiversity metrics. When they did, the amount of metrics disclosed on average was still low at around four.

A more positive sign is the fact that 55% of firms that reported 2024 data have adopted a climate transition plan, led by companies in Western and Northern Europe. However, EFRAG notes that these transition plans are not standardised and often lack detail. 

"Climate plans remain incomplete," wrote sustainability disclosures expert David Carlin in response to the report. "70% of firms commit to 1.5°C targets for Scope 1 and 2 emissions – but just 40% extend that ambition to Scope 3. Only 55% disclose a transition plan at all, and most omit key elements such as funding or levers."

Data comparability

The analysis also shows that the ESRS are supporting high-level comparability of data, despite wide variability in sustainability report structure and length. All statements were structured according to the ESRS General Disclosures and to the Environmental, Social and Governance categories of topical standards, though there were slight differences in the choice of chapter names. In addition, most companies used the list of topical standards, sub-topics and sub-sub-topics provided in the ESRS Application Requirement 16 (AR16), which led to a “good comparability of results at a high level”, EFRAG notes.

However, the granularity of data and reporting style showed wide variations: while the average length of sustainability statements is 115 pages, the longest statement has around 440 pages and the shortest just 25 pages. EFRAG adds that some reports used a longer, more narrative form and others were shorter and more schematic. 

There was also wide variety in the format and content of data point-level disclosures.