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Beyond compliance: Enhancing trust through reporting

Observations on practices following Wave 1 of CSRD reporting

The implementation of the Corporate Sustainability Reporting Directive (CSRD) marked an important moment for businesses in the EU and beyond, transitioning sustainability reporting to mandatory standardized disclosures.

This report, based on an analysis of 200 Wave 1 CSRD reporters across many industries and geographies, reveals both the strategic opportunities and challenges.

For many of the organizations that reported in the first wave, mandatory reporting is not a starting point but a continuation of an ongoing journey. These companies have been developing sustainability strategies and setting targets, and embedding sustainability principles into their business models for many years. Mandatory reporting under sustainability standards has further formalized and codified these efforts—bringing greater consistency, comparability, and assurance to existing practices.

On the whole, most reporting organizations (reporters) found the transition to mandatory reporting under the CSRD more demanding than anticipated, highlighting the need for robust data management systems, cross-functional collaboration, and a cultural shift toward integrating sustainability into core business operations. 

Early adopters are going further, leveraging mandatory sustainability reporting as a catalyst for innovation and differentiation. In particular, identification of sustainability impacts, risks and opportunities (IROs) and double materiality assessments (DMA) are emerging as strategic tools. These tools help organizations align sustainability efforts with risk management and growth opportunities, while carefully managing stakeholder expectations.

Deloitte Global’s analysis evaluates CSRD reporting practices across five industries—Financial Services; Consumer; Technology, Media and Telecommunications; Energy, Resources and Industrials; and Life Sciences and Health Care—and highlights industry-specific trends, challenges, and areas of opportunity.

Insights and key recommendations include prioritizing DMA integration with strategy and risk management, setting ambitious and dynamic targets linked to supportable actions, fostering cross-functional collaboration, building a strong foundation of sustainability data, and engaging proactively with stakeholders across the value chain.

The CSRD represents a pivotal shift, with mandatory disclosure and assurance driving transparency and accountability in sustainability reporting. For organizations willing to embrace this change, sustainability reporting becomes more than a requirement—it can be a catalyst for innovation, resilience, and trust.

Jeff Schwartz, Deloitte Global Non-Financial Reporting Disclosures co-leader

The CSRD has moved sustainability reporting to mandatory standardized disclosures on sustainability IROs across the EU and beyond. While for some organizations this represented a further formalization of practices that have been evolving for many years, for others it can initiate a pivot in how IROs are managed. While the CSRD’s purpose is to enhance transparency and comparability, many organizations are leveraging the inputs and outcomes to inform strategic decision-making. However, the EU’s approach to sustainability regulation is evolving. In early 2025, the European Commission proposed reforms to simplify reporting and reduce burden, highlighting a shift toward more proportionate regulation.

Many leading organizations have been reporting on, and integrating sustainability into decision-making for years, referencing international frameworks such as the Global Reporting Initiative (GRI), the guidance of the Task Force on Climate-related Financial Disclosures (TCFD), or the International Integrated Reporting Framework. For these organizations, CSRD is not a beginning, but the next chapter in a long-standing journey of responsible business. Other organizations have found the transition to CSRD reporting more demanding than anticipated. Integrating sustainability and financial data, building processes, and coordinating data collection efforts across business functions can require significant investment and cultural change.

Meeting mandatory sustainability reporting requirements can also bring an important strategic opportunity. By adopting a structured and robust approach to sustainability data collection, organizations can unlock powerful insights. When combined with the capabilities of Generative Artificial Intelligence, this data can become a force multiplier, helping to empower leaders to make smarter decisions, plan more effectively, and adapt to new ways of working with greater agility. Regulatory reporting can serve as a catalyst for global business transformation, helping forward-looking organizations thrive in an increasingly uncertain and rapidly evolving world.

The CSRD establishes a framework for corporate sustainability reporting, creating important transparency for both internal and external stakeholders. It also compels organizations to make meaningful progress on their actions and programs to become a more sustainable business.

Laurent Vandendooren, Deloitte Global Non-Financial Reporting Disclosures co-leader

Each of the recommendations in this report echoes what leading organizations are doing today to move from compliance to strategic value:
  1. Embedding sustainability into core business functions
    Embed sustainability into core business planning and execution across legal, finance, risk, operations so it becomes a driver of strategic priorities, performance management, and capital allocation.
  2. Using the assessment of IROs as a strategic tool 
    Leverage materiality assessments to prioritize the sustainability matters most critical to both business success and stakeholders—shaping KPIs, investment decisions, and risk mitigation.
  3. Investing in scalable, integrated data systems
    Build flexible, composable data and technology architectures that enable reliable, transparent, and real-time reporting. This foundation supports regulatory compliance, stakeholder trust, and internal decision-making.
  4. Setting bold and adaptive targets
    Move beyond short-term metrics. Define forward-looking measurable targets that are regularly reviewed, linked to incentives, and supported by accountability. Credibility is enhanced when targets are science-based, when appropriate.
  5. Operationalizing sustainability data
    Treat non-financial data as a strategic asset. Embed sustainability metrics into scenario planning, capital expenditure decisions, and performance management cycles—not just annual reporting.
  6. Engaging early across the value chain
    Proactively involve suppliers, collaborators, and stakeholders to help surface IROs, improve data quality, and enhance transparency and enhance shared action.
  7. Driving collaboration across functions through an effective governance structure
    Establish clear governance and accountability structures to enable effective cross-functional collaboration across sustainability, finance, legal, risk, and technology to ensure clear ownership, consistency, and operational follow-through in reporting and action.
  8. Adopting a mindset of continuous learning
    Treat mandatory sustainability reporting as a capacity-building journey. Organizations that embed continuous improvement and upskilling are often more agile in responding to regulatory evolution and shifting stakeholder expectations.

To learn more, read the full report.

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