Q1 2025 marked the release of the first wave of sustainability statements prepared under ESRS, coinciding with the European Commission’s release of its first set of Omnibus proposals.
Even against the backdrop of the Omnibus proposal, companies worldwide increasingly value their sustainability reporting as they realize that not only is this a good way to demonstrate their commitment to positive environmental and social impact, sustainability reporting also helps them to be resilient in a rapidly changing world.
First-wave 26
This publication presents insights from analyzing 26 first-wave CSRD reports from companies in the Netherlands. We explore how organizations are navigating the new requirements, what their disclosures reveal about the level of ESRS alignment and what lessons we can draw.The report is structured around key environmental, social, and governance (ESG) themes – each chapter delving into our most important observations. Beyond comparing numbers, the report aims to draw learning and better practice from what was observed, that can be leveraged to improve next year’s (voluntary or mandatory) reporting.
The Omnibus Proposals
The Commission’s proposals represent a first step towards reducing sustainability reporting requirements in the EU. Striking the right balance between stakeholder needs and the costs to preparers while maintaining the spirit of the EU Green Deal will be a delicate exercise.
Entity-specific matters
The most frequent matters broadly related to:
- Market & Innovation, 30%
- Cybersecurity & Data privacy, 25%
24
Companies have net-zero targets - only 10 were validated by the SBTi
Business conduct (G1) is material for 88% of companies
The most commonly reported sub-topics under G1 are corruption & bribery, corporate culture and whistleblower protection.
Only
50%
of companies comply with the minimal disclosure requirements for Biodiversity
