Danish Large Cap CSRD Benchmarking

Danish Large Cap companies demonstrate a strong CSRD/ESRS reporting foundation, slimming down sustainability statements, pinpointing truly material topics, embedding sustainability operationally, and identifying common areas for development.

Danish Large Cap companies has now published their second year of formal CSRD reporting. Many have embedded learnings from their first year, resulting in a general trend toward slimming down sustainability statements, pinpointing truly material topics (rather than over-reporting), embedding sustainability operationally, engaging with stakeholders internally and across the value chain, and pushing toward designing and embedding ESG controls (similar to financial controls).

In our second benchmarking report, we summarize trends and insights from our CSRD benchmarking assessment covering 37 companies - the Danish Large Cap companies whose sustainability reports were published in accordance with CSRD and ESRS at the time of the benchmark. This assessment captures sustainability insights from the Danish corporate sphere and key changes compared to the first year of CSRD reporting.

As companies in Denmark prepare for the next reporting cycle, the benchmark provides a practical baseline for assessing current practices for identifying priorities for further improvement. The findings point to opportunities to strengthen data governance, improve transparency around targets and resources, and make reporting more focused, comparable and decision useful.

Key insights from benchmarking outcomes and data

1. Report length reflects materiality focus

Danish FY25 sustainability reports averaged 67 pages, down from 73 in FY24, reflecting a slimmer post–year-one CSRD approach. Lengths ranged from 38 to 110 pages, showing varied depth under the same framework. Compared with European peers, Danish reports are generally shorter and more focused on business value, decision usefulness, and material topics.

2. Environmental disclosures remain the most detailed and data-intensive

Environmental content averages 38% of report pages, four times the length of the Governance section. This reflects the complexity and data demands of environment disclosures covering transition plans, scenario analysis, and EU Taxonomy disclosures, making environmental reporting particularly resource-intensive.

3. Decline in materiality recognition for security topics despite increasing cybersecurity risks

Despite rising global geopolitical, technological, and cyber risks, Danish companies gave less prominence to data- and cybersecurity as material topics in FY25. While particularly relevant to sectors such as Financial Services, this may reflect operational risk being reported outside sustainability statements—or a gap between digital risk exposure and disclosed impacts and risks. As digital threats and responsible-technology expectations evolve, more mature disclosures on data, cybersecurity, technology, and AI, supported by stronger materiality assessments, are likely to gain importance.

4. Increasing maturity in climate target-setting but a credibility gap in financial investments

All 37 companies disclose climate actions and quantifiable targets, with 95% reporting transition plans and 59% having SBTi-validated targets. Yet fewer than half quantify the investments supporting these plans, creating a “credibility gap” between ambition and execution. While climate commitment is widespread, the financial backing, transparency, and evidence needed to substantiate progress remain immature across FY25 reports.

5. Danish companies still reliant on fossil fuels despite renewable energy adoption

Danish companies report an average energy mix of 45% renewable energy, 50% fossil fuels, and 5% nuclear or other sources, underscoring the significant decarbonization journey ahead. Although renewable adoption has steadily increased, from 42% in FY24 to 45% in FY25, the continued dominance of fossil fuels highlights the challenge of transitioning to more sustainable energy mixes.

6. Sustainability data quality is improving, but control transparency is declining

In FY25, all companies restated prior-year data, reflecting significant efforts to improve data quality in the second year of CSRD reporting. However, reduced disclosure on control-environment maturity suggests companies are prioritizing operational fixes over transparency and structural accountability.

7. ESG remunerations are more present in long-term incentives (LTIs) than short-term incentives (STIs)

Danish Large Cap companies generally assign greater ESG weightings to long-term than short-term incentives, despite wide variation in design and execution. However, several do not disclose actual ESG or climate payouts, limiting accountability and making it difficult to assess whether incentives are driving intended change.