Early analysis of 250 corporate sustainability statements reveals where companies across industries see risks and opportunities.
What started in February 2025 as a trickle has turned into a steady stream, as hundreds of companies based or listed in the European Union publish sustainability statements under the EU Corporate Sustainability Reporting Directive (CSRD). This matters because the CSRD is not merely a technical reporting exercise. It is primarily an attempt to drive behaviour change: the directive requires companies to thoroughly assess and disclose business risks and opportunities across a wide range of sustainability topics, alongside the impacts of the company on broader society and the environment. Value creation and value protection are at stake.
We think this makes CSRD reporting something that every executive should pay attention to. Investors certainly will be taking note. In PwC’s Global Investor Survey 2024, more than 70% of respondents agreed that companies should incorporate sustainability directly into corporate strategy. And though some aspects of the reporting rules are in flux, basic principles such as double materiality are unlikely to change. (See ‘About the CSRD,’ below, for more background on the regulations, including recently proposed changes.)
At this early stage, key questions for executives, investors and other users of sustainability statements include:
What sustainability risks and opportunities (for the business) and impacts (on people and the environment) are companies identifying?
What patterns are emerging within and across industries?
How should companies move forwards in a regulatory environment characterised by continual change?
To find answers, we reviewed 250 published CSRD statements using a combination of AI-enabled tools and the expertise of PwC colleagues. Of these, more than 70% were from companies in five European countries, three of which (Germany, Spain and the Netherlands) have not yet transposed the CSRD into law. In other words, the companies in these countries were not under a legal obligation to report under the directive but chose to do so—presumably because they buy the argument that good sustainability reporting is a platform for making smarter, informed decisions across the business.
During our review, it quickly became clear that many companies are still coming to grips with the new reporting regime. For example, some companies reported fewer than ten impacts, risks and opportunities (IROs), whereas others disclosed more than 120. To be clear, more IROs does not necessarily indicate a superior sustainability statement. Some variation is to be expected, based on the scope and complexity of the businesses. Even so, we expect to see greater consistency in years to come as companies gain more experience with the reporting standards, as best practices emerge and as stakeholders make their voices heard.
What’s in scope, for whom?
The European Sustainability Reporting Standards (ESRS) that underpin the new reporting regime include ten topical standards covering distinct environmental, social and governance topics. As expected, in the statements we reviewed, the topics most frequently included were climate change, own workforce and business conduct. Almost every company disclosed at least one impact, risk or opportunity for each of these.
Only two companies (a services business and a software company) did not include disclosures related to climate change. As required by the reporting standards, they duly explained why climate did not meet the materiality threshold as an impact, a risk or an opportunity for their company or its stakeholders.
The least common reporting topics were biodiversity and ecosystems (46%), pollution (42%), water and marine resources (36%), and affected communities (31%). This was in line with the results of PwC’s Global CSRD Survey 2024, in which we asked executives about the topics likely to be within the reporting scope for their company.
Beneath these aggregate numbers, clear patterns appeared across industries. For example, only a small minority of technology, media and telecommunications (TMT) companies included disclosures related to biodiversity and ecosystems (9%), water and marine resources (6%) or pollution (3%). In contrast, around half of industrial and services companies disclosed at least one impact, risk or opportunity on each of these topics.
Digging down into sustainability subtopics and sub-subtopics defined by the reporting standards, we see that more than half of companies in consumer markets (61%), energy, utilities and resources (57%), and industrial and services (53%) made disclosures relating to the health and safety of their own workforce. Fewer than one in ten (9%) financial services companies did so.
What of the outliers—the TMT companies disclosing on pollution, or the financial services companies disclosing in relation to workforce health and safety? Do these disclosures reflect atypical business models, idiosyncratic interpretations of the reporting standards or astute identification of material issues that other companies missed? The CSRD statements of competitors are worth reading to learn where companies’ approaches vary, and how others in the same industry may be operating within the new standards.
The financial lens: Risks and opportunities
The CSRD requires companies to disclose the potential effects of sustainability on financial performance in terms of risks and opportunities over the short, medium and long term. For many executives and investors, these disclosures are at the heart of the new regime—where sustainability reporting speaks directly to value protection and value creation.
According to a simple count, most companies see more material, sustainability-related risks than opportunities. For some topics, this is hardly surprising. Consider, for example, the array of pressing climate change and energy transition risks facing businesses today.
On the other hand, companies across industries also disclosed value creation opportunities arising from changing customer needs and preferences in response to climate change, greater awareness of environmental and social issues, and emerging technologies. Against this background, we were surprised to read CSRD statements from more than one large company that disclosed zero opportunities.
The societal lens: Positive and negative impacts
Under the CSRD, companies must disclose actual or potential impacts on people or the environment, considering both their own operations and their wider value chains. These impacts can be positive or negative. In our sample of 250 sustainability statements, we counted 47% more negative impacts than positive impacts. Across industries, only financial services companies, in aggregate, disclosed more positive impacts.
As with opportunities, however, we were surprised to read statements from some large companies that disclosed zero positive impacts. We feel this pattern is likely to change as companies gain more experience and confidence with the regulations.
We also noted many companies disclosing impacts on people and the environment without associated risks or opportunities for the business. For example, we counted more than 300 impacts relating to business conduct (which covers issues as varied as corporate culture, lobbying activity and whistleblower protections) and 180 climate change impacts without risks or opportunities. If these companies are also reporting under the sustainability reporting framework from the International Sustainability Standards Board (ISSB), their ISSB reporting may look different from their ESRS reporting. The ISSB standards require disclosure of information about risks and opportunities. So, for example, in a situation in which an entity has identified an impact associated with climate but has not identified any risks or opportunities, its ISSB reporting may not include information about climate change.
Taking the temperature on climate change
As previously noted, almost every company in our sample disclosed impacts, risks or opportunities related to climate change. Almost all disclosed more risks than opportunities, and this pattern was consistent across industries.
Almost 70% of companies disclosed their targets for reducing greenhouse gas (GHG) emissions. In the energy, utilities and resources sector and in the industrial and services sector, only around half did.
Similarly, though nearly three-quarters of all companies in the analysis described their climate transition plan, this percentage was lower in the financial services sector. A common message from financial services companies was that their transition plan was still a work in progress. Many focused their climate disclosures on actions they were taking to reduce Scope 3 emissions (which include GHG emissions associated with lending and investing).
Looking at Scope 3 disclosures across industries, we see that most companies included disclosures relating to business travel, fuel and energy-related activities, and purchased goods and services. Beyond these common categories, there were again distinct patterns. For example, almost three-quarters of financial services companies made disclosures relating to investments—typically financed emissions—whereas 15% of companies in health industries did so.
Ones to watch: Cybersecurity, AI, tax and other entity-specific disclosures
Companies are obliged to make an entity-specific disclosure if they identify a material impact, risk or opportunity not sufficiently covered by one of the ten ESRS topical reporting standards.
In the statements we reviewed, one in five companies (20%) made entity-specific disclosures relating to cybersecurity and data privacy. This makes sense in the context of investor interest in the topic. In our latest global survey of investors, about a third (36%) said companies would be highly or extremely exposed to cyber risk in the year ahead.
A small number of companies (2%) made disclosures relating to artificial intelligence, with most highlighting their Responsible AI practices and including AI as an opportunity for the business, a potentially positive impact on broader society or both. A couple of companies highlighted AI as a risk or as a potentially negative societal impact.
Innovation is another topic on which some companies (8%) disclosed positive impacts or opportunities for the business. Some highlighted how innovation was making their products more sustainable; others described positive societal impacts arising from their ongoing investment in research and development.
Around 5% of companies included tax-related disclosures, some as a governance matter under the business conduct reporting standard and some as an entity-specific disclosure. These disclosures included qualitative discussion of corporate tax policy and governance, quantitative breakdown of the company’s total tax contribution and other topics.
Worth noting here is that public country-by-country tax reporting will be mandatory starting in 2026 for many European companies under the EU’s tax transparency initiative. In this context, it’s understandable that some companies would start early by including country-by-country information in their sustainability statement.
A first look at assurance
The CSRD asks for independent assurance of sustainability statements at a limited assurance level. Some companies have gone further by opting for reasonable assurance (the level investors seek for financial statements) over a particular subset of information—usually greenhouse gas emissions or own workforce data. One company in our sample opted for reasonable assurance over the full sustainability statement.
Only a small number of the CSRD statements we reviewed had a qualified conclusion from the assurance practitioner. Many contained Emphasis of Matter, Other Matter and Inherent Limitation paragraphs, with assurance practitioners drawing attention to matters such as high levels of measurement uncertainty on certain quantitative metrics, difficulties comparing sustainability information among entities and over time, and the double materiality assessment process.
Conclusion
By necessity, the data and observations in this article are general. Close reading of the reports themselves reveals a wealth of detailed information and insight. It also reveals that many companies within the scope of the CSRD are just starting their sustainability reporting journey, while others already have years of experience.
These are early days for the CSRD. The ultimate yardsticks of the directive’s success will be whether users of sustainability statements (notably but not only investors) find them useful, and how leaders choose to use data from the reporting process to make better decisions on new products and services, more efficient energy use, supply chain reconfiguration, tax planning and other matters.
A final data point for the optimists among us: 80% of the companies in our sample mentioned sustainability-related risks in the risk factors section of their annual report, alongside financial risks, operational risks and so on. This suggests that sustainability is increasingly being woven into mainstream discussions of risk, return and value creation. High-quality reporting under CSRD can only accelerate this process.
