EFRAG publishes initial state of play on first sustainability statements under ESRS

The report is accompanied by a portal that brings together two interactive tools: 

• a report repository; 
• a statistics dashboard allowing users to explore and filter the data analysed using a range of criteria (country, financial or non-financial undertakings, business sector, size based on turnover for non-financial undertakings or total assets for financial undertakings). 

The purpose of this analysis is to inform stakeholders about observed trends, challenges encountered, and areas for improvement, while feeding into discussions on the development of ESRS standards in light of the forthcoming revision and simplification of Set 1 (see this issue’s study on EFRAG’s publication of exposure drafts relating to the revised draft standards). 

Non-financial undertakings, mainly from the manufacturing sector, are strongly represented in the sample analysed by EFRAG (83%). Financial institutions, which account for 17% of the sample, are mainly banks. The most represented countries are France (16%), Germany (13%) and Finland (12%), with a notable presence of entities located outside the European Union (3%), particularly in Switzerland and the United Kingdom. This geographical diversity illustrates the widespread adoption of ESRS standards, including by companies based in countries that are not subject to the CSRD or that have not yet transposed the directive into national law, reflecting the growing importance of transparency in sustainability reporting. 

The key findings highlighted in EFRAG’s press release are as follows: 

• Materiality coverage: only 10% of companies identified all 10 topical ESRS standards as material. Climate Change (E1), Own Workforce (S1), and Business Conduct (G1) were the most commonly disclosed; 
• Stakeholder engagement gaps: 97% of undertakings involved internal stakeholders in their materiality assessment, while engagement with broader societal stakeholders remains rare; 
• Transition plans: 55% of companies disclosed a climate transition plan, though approaches and formats vary; 
• Reporting length: sustainability statements vary widely in length (depending on countries, from 70 to more than 200 pages on average) with financial institutions producing longer reports on average; 
• Underreported topics: disclosures on biodiversity and internal carbon pricing remain limited. Human rights incidents are rarely reported. 

State of Play 2025 report