The promise and reality of CSRD reporting

As we’ve argued elsewhere, the directive is not only a major new reporting obligation but also an opportunity for leaders to understand in greater depth how sustainability will challenge today’s business models and create opportunities for growth and reinvention. The survey suggests that companies are starting to appreciate this upside potential. In addition to the indirect benefits noted above, about one-third of survey participants expect CSRD implementation to lead directly to revenue growth and cost savings. Significantly, those further along in their implementation journey are more optimistic about the business benefits across all dimensions (see chart).

Although many companies produce annual sustainability reports—and report against other sustainability frameworks—the processes that support these disclosures typically need to be extended and strengthened to meet the demands of the CSRD. The directive asks companies to report not only on the sustainability of their own operations but also on the entire value chain, and across a wider range of topics than most have considered until now. In addition, the need for investor-grade reporting requires processes that are repeatable, well-documented and assurable by independent auditors or other third-party assurance providers.

So, how are companies progressing with implementation in the face of the CSRD’s broad scope and complexity? Although respondents to our survey express a high degree of confidence, their answers also reveal potential challenges—including low completion rates for some early-stage activities, lack of senior stakeholder involvement at some companies and low rates of adoption for technologies that support efficient ongoing reporting.

As noted, an overwhelming majority of survey respondents are at least somewhat confident they will be ready to report under the CSRD by the required date. Among those expecting to file in FY2025, only 3% say they are not confident (see chart).

Dig a little deeper, however, and confidence differs greatly not only among companies but also among topics laid out in the reporting standards. Respondents report high confidence on topics that are generally included in existing disclosures (e.g., workforce, business conduct and climate change) but are far less confident in their ability to meet reporting requirements on less familiar topics such as biodiversity, circularity, pollution and workers in the value chain (see chart).

In addition, only a minority of companies have completed upfront scoping activities, even among those reporting in FY2025 (see chart below). The survey results suggest that making progress with scoping breeds confidence. For example, among the most confident companies, more than one-third have finished confirming reporting options and exceptions, completing double materiality assessments, and completing disclosure gap analyses. Those at the start of their journey are less confident.

Crucially, these upfront scoping activities determine whether the company will report at the consolidated group level or at the level of an individual entity, and therefore also determine what data is needed, on which topics, from which sources, and on what timeline to satisfy their reporting obligations. Only then can teams create concrete work plans. In our experience, companies find the CSRD less daunting once they understand in detail how the reporting standards impact them. Among survey respondents, 75% say they plan to comply with the CSRD at the consolidated group level.

Double materiality assessment of impacts, risks and opportunities (IROs) is the mechanism through which companies determine which aspects of sustainability are material to their business and to stakeholders and, therefore, need to be included in their CSRD reports. We asked respondents how many IROs they were evaluating, before and after applying a materiality threshold. The percentage of companies evaluating more than 100 halved after applying materiality, while the percentage of companies evaluating fewer than 20 doubled (see chart below).

The wide range of responses underscores that the number of topics on which companies report will vary enormously, as it should, depending on the size, business model and value chain complexity of the company. In addition, assessments of impacts, risks and opportunities are somewhat subjective even with detailed reporting standards in place. We expect to see some convergence between similar companies in future years as companies gain more experience working with the standards and as best practices continue to emerge.  
 

Regardless of the scope they ultimately decide upon, companies say that data availability and quality are the biggest obstacles to implementation (see chart below). The breadth and depth of CSRD reporting presents a massive challenge as teams work to collect, verify and consolidate many new types of data. Much of this information does not exist today in companies’ enterprise resource planning (ERP) and other central source systems. It must be tracked down manually from spreadsheets and original documents (e.g., invoices) that are distributed across the enterprise. This is a recipe for inefficient and error-prone processes, unless companies pay close attention to the fundamentals of data strategy—how sustainability data is defined, sourced, governed and processed.

The CSRD’s requirement to look across the value chain presents an additional data-related challenge. Often for the first time, companies must use data from suppliers, customers and third-party data providers, and they need to assess their reliability. Even the first step, understanding and defining the value chain for the purposes of the CSRD, takes considerable time. It is no surprise, therefore, that survey respondents identify value chain complexity as the second-biggest obstacle to implementation.

In our experience, a major cross-functional effort under the sponsorship of senior leaders is needed to address the CSRD’s broad scope and complexity. Survey respondents report on average that eight business functions and departments either are currently involved or will be involved in their implementation effort, typically including sustainability, finance, operations, procurement, technology and legal.

Given the requirement for assurance under the CSRD, an assurance provider should be involved from an early stage. Most companies appear to have understood this. Almost 80% of respondents say they have engaged an assurance provider, either their financial auditor (49%), a different audit firm (14%) or another third-party assurance provider (16%).

Executive committees or boards are currently involved in CSRD implementation at more than 70% of companies, and this proportion rises to almost 80% for those planning to report in FY2025 (see chart below). Although this is encouraging, we urge teams who have not yet engaged with these senior stakeholders to do so as soon as possible, especially at companies aiming to report in 2025. Without strong governance—driven from the top, and including clarity on roles and responsibilities across business functions—there is a danger that implementation efforts will stall.

Among executive committee members, chief financial officers (CFOs) and chief information officers (CIOs) should play central roles supporting chief sustainability officers (CSOs), who in many cases have been leading sustainability reporting efforts thus far. CFOs, as custodians of existing financial reporting processes, ‘know what good looks like’ when it comes to investor-grade disclosures. In our experience, CSOs who engage the finance function can focus more effectively on their areas of distinctive expertise: helping the company realise sustainability-led opportunities and mitigate risks.

Although most respondents plan to involve the technology function, less than 60% have already done so. In our experience, it is helpful to have technology colleagues at the table from an early stage so they can start to consider how to incorporate emerging requirements into road maps for new or upgraded systems. Although not every company is ready to embark on a major investment programme, targeted technology investment, building on existing cloud and ERP foundations, is ultimately the only way to achieve efficient ongoing reporting and feed sustainability data into decision-making processes across the enterprise.

Without such investments, organisations will need to continue to rely substantially on manual processes. Asked about their use of technology tools, more than 90% of survey respondents say they are using, or planning to use, spreadsheets for sustainability reporting, a far higher percentage than are leveraging technology such as sustainability data lakes, disclosure management solutions and carbon calculation tools (see chart below).

We expect these results to change significantly in coming years as more companies invest in solutions that ensure efficient, repeatable reporting, while also feeding sustainability-related data into decision-making processes across the business. Equally, we expect the number of respondents using AI tools for sustainability reporting to increase substantially.

The CSRD is part of a broad effort by policymakers—not only in Europe but also in the United States, Australia, China, and other countries and territories—to steer economies towards a sustainable, low-carbon future. Besides new reporting requirements and other sustainability policies (for example, the EU Carbon Border Adjustment Mechanism and Australia’s Safeguard Mechanism), governments have established major spending programmes. Fiscal initiatives such as the US$370 billion US Inflation Reduction Act and the European Commission’s US$270 billion Green Deal Industrial Plan aim to stoke demand for low-carbon goods and services, and to encourage investment in the industries that supply them.

Without doubt, this activity will generate value-creation opportunities for business—if leaders bring sustainability into their strategies and planning. This is where CSRD reporting efforts pay off. The work of collecting sustainability data and preparing disclosures can provide executives with information to make better business decisions. Our survey confirms that many businesses are starting to understand this potential, even as some continue in a compliance-only mindset.

In our experience, three actions can enable CSRD readiness as well as deeper integration of sustainability with strategy:

• Move now to understand your scope, while recognising the progress you’ve made already. The CSRD and the accompanying ESRS may be new, but plenty of companies have been disclosing sustainability information for years, under regulatory mandates or voluntary standards. To do that, they have performed activities (such as stakeholder engagement and materiality analysis) and set up processes (such as data collection) that can be leveraged for the CSRD. At the same time, companies that have not completed upfront CSRD scoping should consider accelerating this effort. Only then will they fully understand the challenge they are facing—and be able to make concrete plans. Interacting with industry peers and partners will illuminate how others are approaching less-familiar aspects of the new reporting standards, such as double materiality.

• Set up your data processes and systems for the long haul. In our survey, relatively few respondents say their companies currently keep sustainability information in central systems. Although we didn’t ask about the use of central systems in other business domains, we’ve seen that they’re commonly applied in areas such as finance, customers, products and human capital—areas where reliable information has long been seen as essential for decision-making and for external reporting. Savvy executives recognise that sustainability information, too, must be available, accurate and audit-ready: not just on a one-time basis, but annually. They are making investments in data and systems comparable to the ones they use in financial reporting.

• Get your top executives involved. As noted, cross-functional collaboration on CSRD readiness is already the norm. Leading enterprises make sure that collaboration happens at the highest level, organising the CFO, the CIO and the CSO into a power trio responsible for CSRD implementation. Supported by their respective teams, CFOs bring knowledge of how the company manages information and makes decisions, CIOs direct the installation of enabling data systems and software, and CSOs provide expertise in sustainability topics and CSRD-specific procedures such as double materiality assessment. The combination of these skills is essential not only to meeting compliance requirements but also to embedding sustainability into discussions about the company’s operations and business model.

Overall, remember that reporting under the CSRD and ESRS is a journey for everyone involved—regulators included. In the early years, reports will likely differ in significant ways among similar companies as stakeholders converge on a common understanding of best practices. What matters most at this stage is serious engagement by senior leaders to understand not only the CSRD’s detailed requirements but also its intent—and the opportunities it reveals for value creation.  

About the survey

In April and May 2024, PwC surveyed 547 executives and senior professionals across more than 30 countries and territories. About one-third of respondents hold C-suite roles, and the remainder are senior professionals across business functions including sustainability, finance and risk. Sixty percent of companies represented are headquartered within the European Union. More than half have annual revenues of over US$1 billion. Sectors represented included manufacturing (25%); financial services (21%); technology, media and telecommunications (18%); consumer and retail (14%); energy, utilities and resources (13%); and healthcare (7%). Across all respondents, 57% say they will file under the CSRD for the first time in the 2025 financial year, based on FY2024 data. Unless specified, charts include all respondents (547).