Insights from the first sustainability reports of Dutch listed companies - Part 1

In this article we will discuss the following key points:

• Majority of Amsterdam Stock Exchange listed companies voluntarily published full CSRD compliant reports.
• Sustainability statements are much longer than sustainability reports from previous years.
• Main reported ESRS standards relate to E1 ‘Climate Change’, S1 ‘Own workforce’ and G1 Business Conduct’.
• Significant increase in reported sustainability matters reported when compared to previous reporting.
• Stakeholder engagement has been broad, covering 12 twelve broad categories.
• Some progress has been made on climate action and a significant number of companies have developed climate transition plans covering key aspects.

Majority of Amsterdam Stock Exchange listed companies voluntarily published full CSRD compliant reports

Based on our analysis (85 reports published from 1 January to 14 April 2025), 72 “Wave 1” companies have published a fully compliant CSRD report. Although CSRD has not been transposed to Dutch law, these companies have voluntarily reported in line with the requirements of the European Sustainability Reporting Standards (ESRS) and have obtained at least limited assurance. Four companies have opted not to report on a voluntary basis, one of which would be excluded from reporting if the 1.000 FTE threshold proposed in the Omnibus Content proposal is implemented. At least nine other companies have published partially updated reports in preparation for CSRD reporting. Although after the Omnibus, all nine are likely to be excluded from mandatory reporting because they have fewer than 1,000 employees.

Please note that for our further analysis, we only included fully compliant disclosures of 72 Dutch companies, unless specifically stated otherwise.

Sustainability statements are much longer than sustainability reports from previous years

As has been widely reported across Europe, complying with the extensive set of data points in ESRS has significantly increased the scope of sustainability statements compared to previous years. Dutch sustainability statements now average 91 pages long (minimum 38 and maximum 217), compared to pre-CSRD reporting averaging 36 pages in 2023. This is based on a sample of 49 listed companies.

Main reported ESRS standards relate to E1 ‘Climate Change’, S1 ‘Own workforce’  and G1 ‘Business conduct’

The manufacturing (29), financial services (13) and information and communication (6) sectors make up the largest part of the reporting population. S1 – Own workforce (all companies), E1 – Climate change (99%), and G1 – Business conduct (88%) are the most reported current standards, while S3 – Affected communities (28%) is the least reported. There is a diverse spread of reporting within sectors, though as to be expected companies with a large physical footprint generally report on more standards than, for example, information and communication, real estate and hospitality and service sectors.

The diagram below shows a heatmap of reporting in different sectors. A blank cell indicates that none of the reports in the sector included the topic, while fully shaded cells indicate that all reports included the topic.

Significant increase in reported sustainability matters compared to previous reporting

Companies adopted CSRD for the first time, have matured in their processes, and engaged with assurance providers, resulting in more material issues being identified. The average Dutch company reported on 15 material matters this year compared to 11 last year (noting that we analysed 49 reports for the previous year).

Strong focus on negative impacts and risks

On average, 22 Impacts, Risks and Opportunities (IROs) were identified as material. There is significant diversity in how the outcomes of double materiality assessments (DMAs) and sustainability matters and identified IROs are disclosed, making the information difficult to compare. For example, some entities tend to report sustainability matters at a topic level (e.g. climate change), summarising all potential IROs into one item, and making it unclear what the underlying IROs relate to. Risks and negative impacts make up two thirds of all identified IROs. As expected, the financial sector deviates from this, with a much greater focus on risks (61% of all IROs).

Stakeholder engagement has been broad

Based on the published reports, we have identified 12 groups in which the most engagement can be categorised. In the visual below, the identified stakeholder groups are included. The smaller the stakeholder is depicted, the less frequently this stakeholder is involved in stakeholder engagement. 

The level of stakeholder engagement in the different sectors is highest in transport and retail (8 stakeholder groups engaged on average) and lowest in real estate and hospitality (3). Direct engagement (e.g. meetings, one-on-ones) and surveys are the most prominent methods of engagement, although specific forms of tailored engagement are also reported for different stakeholder categories

For employees, this includes town hall meetings and training, annual reporting and conferences for investors, feedback workshops for customers, and use of codes of conduct and contract terms for suppliers. It is our view that bilateral, sustainability-focussed and upfront stakeholder engagement is one of the crucial elements for an effective DMA process.

Some progress has been made on climate action

Despite challenges and setbacks experienced globally in mitigating climate change, it is encouraging to see that 66% of reported companies having climate change transition plans that had at least a Net Zero by 2050 target and mitigation plan. The transition plans indicate embedding in the business strategy and inclusion in financial planning. The transition plans have been approved at the highest level. Another 26% of companies reported having covered at least some of these elements while 5% had already started developing transition plans.

Conclusion

The first published annual reports show that the vast majority of companies have published CSRD compliant disclosures. 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.