First batch of CSRD reports have issues

Here’s a note from Maria Tymtsias:

After reviewing several reports and discussing them with practitioners inside the community, one thing is clear: the reality of CSRD implementation doesn’t always match our expectations.

Here are some of the points highlighted:

🔹 Materiality assessments: a black box?
We expected clear methodologies, thresholds, and explanations. Instead, some reports don’t justify why certain topics were omitted, and even companies in the same industry identified completely different priorities—without any explanation.

🔹 IROs: vague, inconsistent, and buried in text
In some reports, figuring out what the actual impact is feels like for a needle in a haystack. Instead of a clear statement, IROs are buried in beautifully worded paragraphs that make it hard to pin down what the company is actually disclosing. There’s little transparency on how IROs were assessed, how they tie to the value chain, or which ESRS standard and topic they link to.

🔹 Auditors: pushing hard… or letting things slide?
Companies felt heavy pressure from auditors, with strict requirements and deep documentation demands. But then, we see reports missing critical disclosures or providing vague assessments, while still getting assurance. A huge disconnect.

🔹 Governance: where did it go?
One of the biggest surprises was that some companies spent pages explaining how important governance is, only to declare it not material and skip the disclosures. Makes no sense.

🔹 Positive impacts misinterpreted
Some companies reported mitigating negative impacts as positive impacts, even though ESRS clearly says they’re not the same. How did this get past assurance?

🔹 Value chain assessments: missing or unclear
Some reports barely touch on value chain assessment, even though ESRS requires it. Companies state whether an issue occurs upstream, in operations, or downstream, but without explaining how they assess it, who are value chain actors etc.

🔹 Entity-specific topics: strategic move or a loophole?
Some companies introduced entity-specific topics instead of using ESRS categories. In some cases, it made sense. However, in others, it feels like a way to avoid reporting on required topics by shifting disclosures into custom labels. Some even skipped ESRS-defined subtopics while reporting on something nearly identical under their own label.

🔹 No common structure
Without standardized tagging, reports are all over the place. Some are well-organized, others are a mess, burying key details. Even within the same industry, comparing reports is a struggle.

I’ve already been criticized for focusing only on the negatives, but without understanding what’s wrong, we can’t figure out what right looks like.