CSRD goes live: lessons from the first European reports
7 October 2025
The Corporate Sustainability Reporting Directive (CSRD) is a European Union regulation designed to enhance corporate transparency on sustainability. Effective from 1 January 2024, the CSRD requires Wave 1 companies to publish a sustainability statement in 2025 covering the 2024 financial year.
To support CSRD compliance, the European Commission has adopted the European Sustainability Reporting Standards (ESRS). These standards cover all Environmental, Social and Governance (ESG) dimensions, harmonising disclosures and ensuring interoperability with international frameworks to reduce duplicate reporting.
Our study reviewed CSRD-related sustainability statements from 16 insurance and reinsurance companies, 10 of which are based in countries that had already transposed the directive by 31 December 2024. The analysis focused on how companies are approaching CSRD materiality assessments, transition plans and emerging practices.
Key findings on CSRD implementation
- Double materiality analysis (DMA) is central to CSRD reporting. It identifies both the company’s impacts on the environment, people and governance, and the financial risks and opportunities arising from these issues.
- 88% used rating scales to assess impacts, risks and opportunities (IROS)
- 75% applied ESRS-recommended time horizons
- 75% relied on existing mappings
- 100% drew on external studies or analyses
- Environmental standards under CSRD were prioritised unevenly:
- 100% considered E1 – climate change material
- 50% identified E4 – biodiversity and ecosystems
- 38% identified E5 – resource use and circular economy
- 19% identified E2 – pollution and E3 – water and marine resources
- Transition plans required by CSRD remain a challenge. ESRS E1 specifies that a climate transition plan must include:
- Greenhouse gas reduction targets
- Decarbonisation levers and actions
- Investments and financing
- Integration into strategy and planning
- Monitoring and regular updates
Most companies disclosed transition plans, but their scope and alignment with CSRD and ESRS requirements varied significantly, reflecting the sector’s ongoing adaptation to the new regulatory framework.
Download the study below for the full analysis on CSRD reporting.
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Souad El Ouazzani Partner - Paris, France
Jennifer Maingre Coudry Paris, France