Deloitte: How are Companies Approaching CSRD Reporting?

The Corporate Sustainability Reporting Directive (CSRD) has been implemented in the EU, creating mandatory standards for sustainability.

Although the regulation is currently under review, with changes expected to come into effect by the end of 2025, Deloitte has released a report titled "Beyond compliance: Enhancing trust through reporting". 

The report outlines how the CRSD regulations have impacted 200 organisations since it was imposed.

Ivan Kukhnin, Partner for Strategy, Risk & Transactions, Sustainability at Deloitte Netherlands, says: “Drawing on an analysis of 200 organisations in the first wave of mandatory sustainability reporting under the Corporate Sustainability Reporting Directive (CSRD), this report provides data-driven insights into how leading organisations are responding to evolving requirements and leveraging reporting as a strategic advantage.”

What does the report outline?

Deloitte Global says it provides an analysis of 200 CSRD reports from the first wave.

For many organisations, the mandatory reporting was a continuation of things already being done.

Deloitte says that these companies have been developing sustainability strategies and setting targets for years. 

The reports were selected to provide a more balanced representation with a main focus on evaluating reporting practices and trends across industries.

Deloitte's experts have reviewed the reports and picked out key industry observations about how organisations are using mandatory reporting to develop strategic advantage in a business environment. 

Jeff Schwartz, Global Non-Financial Reporting Disclosures Co-leader at Deloitte, says: “The CSRD represents a pivotal shift, with mandatory disclosure and assurance driving transparency and accountability in sustainability reporting. 

“For organisations willing to embrace this change, sustainability reporting becomes more than a requirement—it can be a catalyst for innovation, resilience and trust.”

What were Deloitte's industry insights?

Financial services

Of the organisations analysed, 37 were from the Financial Services industry.

Of those analysed, 90% of banks disclosed financed or portfolio emissions targets which could redirect future lending to lower carbon alternatives. 

The majority in the sector embedded sustainability drivers into enterprise risk frameworks

Reliance on counterparty information is important to finance emission measurement, with the majority of reports referencing the Partnership for Carbon Accounting Financials framework to calculate emissions. 

Banks rarely published scores using PCAF data. The scale indicates that the majority of emission information comes from model estimates or sector averages rather than company reported data

Around half of those assessed reported on biodiversity and ecosystems, but most of the reports disclosed nature related policies, only as all amount set time bound targets related to deforestation-free finance or project-level biodiversity net gain. 

Consumer

The consumer industry had 62 of the companies analysed.

Deloitte reports that, to meet the reporting requirements, companies have had to invest in supply chain mapping and supplier engagement. 

Almost all of consumer organisations disclosed emissions related to purchased goods and services alongside 94% that reported on upstream transportation and distribution emissions.

Within the consumer industry, Deloitte found an emphasis on circular economy and product lifecycles with many disclosing strategies with aims to make products more durable, reliable and recyclable. 

Deloitte also found that there has been a greater use in secondary materials, plastic reduction road maps and refill/repair schemes.

Jennifer Steinmann, Global Sustainability Business Lead, Deloitte said on Linkedin: "I’m very pleased to share Deloitte’s new report that illustrates how leading organisations are turning mandatory sustainability reporting—from CSRD and other regulations—into a catalyst for innovation and growth as well as a source of resilience and competitive edge." 

Technology, media and telecommunications

The TMT industry accounted for 30 of the organisations analysed.

Around 60% of the organisations reported on workers in the value chain, with many established operational controls related to suppliers. 

Most of the attention related to workers was om health and safety lapses, child labour and forced labour, with living wage shortfalls being reported on less.

One third of the TMT reporters disclosed AI or algorithmic bias data and Deloitte says this signals that digital ethics is emerging as a recognised sustainability domain.

The analysis found that TMT reporters rarely disclose information surrounding pollution, water and biodiversity. 

Energy, resources and industrials 

The energy, resources and industrials sector covered 55 of the organisations reported on.

Deloitte reports that there is a focus on value chain emissions and the energy transition, with 30 of the organisations reporting an explicit net zero target for Scope 3 GHG emissions, alongside 51 reporting to have a climate transition plan.

Organisations within the industry were also expected to develop a credible transition plan, with clear roadmaps for renewable energy adoptions and process electrification.

Nearly nine in 10 of reporters disclosed information regarding resource use and circular economy and 73% reported on disclosed biodiversity and ecosystems.

Those in the sector increased tracking specific data relevant to operations on a more granular level, like energy consumption by source, water withdrawal, waste types and safety incidents.

Life sciences and health care

The LSHC industry covered 16 organisations reported on.

Deloitte says the data indicates that organisations reported efforts to expand product access and address health disparities, focusing on vulnerable or low-resource communities and using more inclusive healthcare models.

Around 50% of those in the industry reported on patient safety in clinical protocols, 45% addressed data privacy in trials and around 30% reported on animal welfare in preclinical testing.

Several of the reporters highlighted risks surrounding improper medicine disposal and device waste, although referencing the post use impact most did not include strategies or measurable targets to minimise the risk.

Laurent Vandendooren, Global Non-Financial Reporting Disclosures Co-leader at Deloitte, says: “The CSRD establishes a framework for corporate sustainability reporting, creating important transparency for both internal and external stakeholders. 

“It also compels organisations to make meaningful progress on their actions and programs to become a more sustainable business.”

What are Deloitte's recommendations?

After reviewing all the reports, Deloitte has released recommendations designed to help organisations move from compliance to strategic focus:

• Sustainability needs to be embedded into core business functions to become a driver of strategic priorities, performance management and capital allocation 
• The assessment of IROs should be used as a strategic tool and companies should leverage materiality assessments to prioritise sustainability matters that are most important to business success and stakeholders
• Investment in flexible, composable data and technology is crucial as it is the foundation that supports regulatory compliance, stakeholder trust and internal decision making
• Credibility is enhanced when targets are regularly reviewed, linked to incentives and supported by accountability
• Companies should embed sustainability metrics into scenario planning, capital expenditure decisions and performance management cycles, essentially operationalising sustainability data 
• Early engagement across the value chain, like involving suppliers, collaborators and stakeholders, can help improve data quality and transparency
• Effective governance structures are important to drive collaboration across functions, ensuring clear ownership and consistency over sustainability, finance, legal, risk and technology
• Those that use mandatory reporting as a tool to improve skills and move towards continuous improvement are usually more agile in responding to regulatory evolution.

The company says that this information is not intended as a checklist, but as strategic guidance to embed sustainability in core business operations.

Ivan says: “Wave 1 of CSRD reporting revealed just how much organisations underestimated the effort involved. 

“Unlike financial reporting, there’s no ‘off-the-shelf’ solution—you can’t just plug in a system and move on. Getting it right requires finance-grade discipline, smart use of existing data and cross-functional collaboration. 

“But mandatory sustainability reporting isn’t just about producing one report a year—it’s about continuously driving performance. 

“With the right data, businesses gain the insight to course correct, prioritise investment and make sustainability a core lever of strategic decision-making."