An article by our colleague Vera Kluck,
Consultant for Sustainability Communication & ESG
Every beginning is difficult – especially with a topic as complex as CSRD reporting. 2024 was the first year of application of the CSRD for some companies. How well did reporting companies comply with the European Sustainability Reporting Standards (ESRS), even though their application was still voluntary due to the lack of an implementation law? A recent study by the German Accounting Standards Committee (DRSC) and Deloitte examined 128 sustainability reports from listed companies in Germany (as of 15 May 2025).
Key findings:
- Only 51% of the companies examined fully implement the ESRS requirements.
- The average length of reports prepared in full accordance with ESRS is 130 pages, which is significantly higher than the expected 60-100 pages.
- The majority of reports (77%) were audited with limited assurance, i.e. in a less comprehensive form than the classic audit with reasonable assurance.
- The number of material IROs (impacts, risks and opportunities) varies greatly: between 5 and 118 IROs were identified, with an average of 43 IROs.
Findings that come as no surprise
The study confirms the complexity and large scope of CSRD reports. We have supported companies from various industries in implementing CSRD and have encountered similar challenges.
Particularly striking: ESRS-compliant reporting is significantly more time-consuming than most companies expect. What appears to be a manageable project turns out to be a complex, multi-stage process. Therefore, upstream tasks such as data collection, preparation and validation should be started as early as possible to ensure timely reporting.
At the same time, internal coordination is far more demanding and time-consuming than many expect. Different areas of the company must work closely together – from the sustainability department to controlling and operational units. Diverging perspectives and different data sources collide and must be reconciled. In addition, the existing data basis is often insufficient for the detailed ESRS requirements. Gaps in data collection, inconsistent measurement methods or the complete absence of certain ESG indicators are forcing companies to rethink and expand their entire sustainability data infrastructure.
What can you conclude from this?
Despite the current regulatory uncertainty, companies that systematically work on the quality of their data and optimise reporting processes will benefit in future sustainability reports. In concrete terms, this means analysing existing data collection processes, identifying quality gaps and establishing robust, audit-proof documentation systems.
A basic recommendation for all companies affected by the CSRD to take some of the pressure off: quality over quantity. Instead of getting lost in the variety of possible sustainability topics, it pays to focus clearly on aspects that are truly essential to your business model and your stakeholders.
At the same time, close, continuous cooperation with auditors and relevant internal departments is essential. Companies that involve their auditors in the reporting process at an early stage avoid surprises later on. They ensure that the processes and controls developed will then also withstand the requirements of an external audit.
The DRSC-Deloitte study on the CSRD reports published to date in Germany can be found at the following link (German only):
https://www.drsc.de/projekte/studie-zur-nachhaltigkeitsberichterstattung-2024/
