CSRD Reports Reveal Progress and Gaps on Double Materiality and Risk Disclosure

A new study analyzing 304 CSRD-aligned sustainability reports across 21 countries uncovers a key trend: companies are increasingly disclosing ESG risks with more structure and standardization, yet blind spots still exist. While disclosures related to climate, workforce, and business conduct are well-developed, topics like water, biodiversity, and affected communities are underreported. The findings highlight an important transition for EU sustainability reporting that requires stronger enforcement and contextual clarity. 

Why This Matters 

• The CSRD is becoming the de facto model for standardized sustainability reporting, influencing policy outside Europe as well.  

• A move toward structured, comparable disclosures strengthens the ability of financial institutions to elevate climate and sustainability risks. 

• With negative impacts disclosed nearly 3x more often than positives (37% vs 13% IROs), there is a pressing need for more balanced reporting.  

What the Datamaran Report Shows 

The report analyzed 11,208 individual Impact-Risk-Opportunity (IPO) statements from 304 CSRD-aligned sustainability reports to assess how companies are approaching the new double materiality standard. 

• High disclosure in core ESG areas 

• Climate change (E1 – 99%), own workforce (S1 – 98%), and business conduct (G1 – 92%) are the most reported topics, signaling these as foundational pillars of CSRD-aligned strategies. 

• Reporting gaps in nature and community impact 

• Disclosures on biodiversity, water, and affected communities fell below 50%, indicating persistent gaps in ecosystem and stakeholder risk accounting. 

• Context and specificity still lacking  

•  Despite the increase in disclosure quantity, many reports fall short in providing contextual depth. 

Challenges 

Many companies are still learning how to apply the double materiality lens in practice, balancing financial risk with environmental and social impact. The low reporting rates on biodiversity, water, and communities could undermine emerging regulatory initiatives like the EU Nature Restoration Law and Taskforce on Nature-related Financial Disclosures (TNFD). Finally, the gap between reporting and performance is an ongoing concern: publishing data is not the same as transforming business models. Policymakers and standard setters must reinforce guidance on quality, and investors must continue to push for material disclosures that reflect real risk exposure and transition plans.  

Action Items 

• Companies and issuers must evolve beyond compliance-driven reporting to a more strategic use of the CSRD framework 

• Investor and ESG analysts should view CSRD data as the baseline for engagement, using it to challenge companies on the quality of their sustainability strategy 

• Sustainability consultants and assurance providers can support this transition by helping firms strengthen their double materiality assessments