CSRD Benchmark: Dutch listed companies compared

In this article we will discuss the following key points:

• 90% of the indexed (e.g. largest) Amsterdam Stock Exchange listed companies have voluntarily adopted CSRD.
• There is some correlation between market capitalisation and disclosure length, although the difference is slight between large cap and mid cap companies.
• Materiality rate of topical standards in the Netherlands lower than in France, Germany and Austria.
• IROs of Netherlands companies are more financial materiality-focused than companies benchmarked by Forvis Mazars in France, Germany and Austria.
• Best practice - tips for you.

Introduction and methodology

This article is the second in a series of our observations following the publication of the first round of CSRD reports. The first article can be found on our website. In this second article, we have updated our data and findings up to 15 June 2025, and focus our analysis on the reporting trends of Amsterdam Euronext stock exchange (XAMS) companies.

90% of the indexed (e.g. largest) Amsterdam Stock Exchange listed companies have voluntarily adopted CSRD

Based on our analysis of reports published from 1 January to 15 June 2025, 91 companies have published a fully compliant CSRD reports. In this article, we focus on the reports of the 75 Amsterdam stock exchange companies that make up the large cap (AEX), mid cap (AMX) and small cap (AScX) indexes. The disclosures within the different XAMS indices up to 15 June 2025 is shown in the table below. 

• 57 indexed companies categorised as Wave 1 have issued fully CSRD compliant reports (full ESRS compliance and limited assurance).
• Six Wave 1 companies have not opted to voluntarily publish compliant reports, as the ESRS has not been transposed into Dutch Law. 
• Eight companies are below the threshold of Wave 1, and therefore would not have been expected to report this year.
• There is a small number of companies that have not yet published reports due to delays or having a later financial year end.

 As expected, AEX companies (largest 25 by market-cap) show the highest degree of voluntary compliance, with 23 fully compliant reports published. In this group, one entity opted not to report on a voluntary basis. In the mid cap AMX (next 25), compliance drops slightly to 21 companies. In this group, there are two companies that have opted not to report on a voluntary basis, and two companies that have fewer than 500 employees (e.g. Wave 2/3). In the small cap AScX, 13 companies have published fully compliant reports. Three Wave 1 companies have opted not to report voluntarily, and six are below 500 employees .

Overall, there is a high-degree of voluntary compliance of Dutch XAMS listed companies, with 57 of the 63 (i.e. 90%) Wave 1 companies in the AEX, AMX and AScX indices reporting on a voluntary basis.

Almost two-thirds of the reports analysed were published by companies in the manufacturing, financial services or information & communication sectors, as shown in the figure below. These are also the larger companies  included in our study - 19 of the 23 large cap companies are active in one of these sectors.

There is some correlation between market capitalisation and disclosure length, although the difference is slight between large cap and mid cap companies

As we reported in our previous article, overall disclosure lengths have increased significantly compared to sustainability reports from the prior year. Within the different XAMS indices, AEX disclosures tend to be slightly longer than AMX, and both are significantly longer than smaller AScX companies. In the diagram ‘Page count’, the maximum, average, and minimum number of pages of reports from each index group is shown.

Materiality rate of topical standards in the Netherlands lower than in France, Germany and Austria

The figure below shows the materiality rate of different topical standards (that is, how frequently a topical standard has at least one material IRO and is reported on), comparing our study of Amsterdam listed companies to those of Forvis Mazars in other European countries: France (CAC 40), Germany (DAX) and Austria (ATX). As shown, the Netherlands indexed companies (dark blue) has a lower rate of materiality on many of the ESRS topical standards. It is worth noting that this effect can still be seen even when considering only the AEX-index companies. We note, however, that this can at least be partly explained by the large number of financial services, services and information & communication companies on the Amsterdam Exchange indexes.

IROs of Netherlands companies more financial materiality-focused than companies benchmarked by Forvis Mazars in France, Germany and Austria

It is also worth noting that, compared to these other studies, XAMS companies also trended towards presenting more financially material-IROs (impacts, risks and opportunities) than impact material IROs. DAX and ATX companies tended to report impact material-IROs around 70% of the time, CAC 40 about 53% of the time, while in the Netherlands impact material-IROs only made up 46% of the total. The distribution of IROs in the Netherlands is therefore also more closely aligned to that of France, although the Dutch economy is more closely aligned to that of Germany.

Further, it is a concern that the reporting rate of Opportunities is so low (17% in the Netherlands, and 14% when considering a weighted average of these four countries). Sustainability opportunities is linked to the potential financial benefits the companies see in pursuing sustainability-related business. Given that the size, scale and pace of the transition required to a more sustainable economy, the low rate of reporting of Opportunity IROs would seem to indicate most companies are not yet seeing a business case for sustainability, or at least that these are far less common than risks.

Practical tips for improvement

Some areas for improvement have emerged from the publications produced so far.

• Follow the ESRS structure: The structure provided in ESRS 1 Appendix F and proposed by Paragraph 115 should be followed. This straightforward, simple structure makes it easier for users to navigate to sections relevant to their interests, as well as improving comparability. Similarly, where the ESRS provides structure to follow related to quantitative information (e.g. for the carbon footprint table), this should be followed to improve useability and comparability. Finally, providing clear sing-posting with DR labelling can help users quickly find relevant sections, and is slightly more user friendly than only including an index.
• Follow best practices from established industries: Companies that have not previously reported on extensive sustainability data can benefit from reviewing the reports of companies that have mature reporting structures that have been developed to be easy for the reader to understand.
• Provide complete, distinct reporting of IROs to avoid causing uncertainty: The reporting of IROs can be improved by making them more complete and understandable. We have observed a number of reports where key information is omitted. This included whether an impact is actual or potential, what timeframe an IRO relates to, or where in the value chain it is expected to take place. Further, there are also cases where IROs appear in condensed or aggregated form that can lead to uncertainty for readers.

Conclusion

Listed companies in the Netherlands (Wave 1) have generally opted to continue with publishing fully compliant CSRD reports. The publication of these disclosures has provided some key insights into the breadth, scope and nature of sustainability matters facing companies in the Netherlands. Entities expecting to report in future (e.g. Wave 2 in 2027) can gain valuable insights from benchmarking themselves against these companies. To support our clients in this process, we will continue to monitor and analyse developments in the coming months. For future updates, please keep an eye on our website or contact Ron Horsmans or Annelot Kosman.