CSRD reporting is becoming more confident but less consistent

In brief

The first year of CSRD reporting was defined by compliance.

The second is starting to look different.

A follow-up analysis of early CSRD adopters by Black Sun Global - revisiting the same group of primarily Danish companies first examined in its[initial CSRD study - shows that Sustainability Statements are becoming shorter, more flexible and more communication-led. But it also points to a growing tension: as companies take more ownership of how they report, consistency and comparability are beginning to weaken.

The findings are based on a review of 20 companies that have now completed two cycles of CSRD reporting, offering one of the earliest views of how practice is evolving.

Reports are getting shorter - and more focused

One of the clearest shifts is a reduction in length.

Across the sample, almost all companies shortened their Sustainability Statements, with an average reduction of nine pages. General Disclosures saw the most significant cuts, driven by tighter narrative and the removal of duplication.

This reflects a broader move away from volume towards clarity. Rather than expanding disclosures, companies are starting to refine them - focusing on what matters and how it is presented.

The structure is starting to loosen

In the first year, most companies followed the ESRS framework closely.

That is beginning to change.

Companies are reordering standards, introducing summary sections, and testing different ways of structuring content to improve usability. Some are grouping disclosures by priority rather than by regulation, while others are rethinking where technical sections sit within the report.

This suggests that the framework is more flexible in practice than many expected. But that flexibility comes with trade-offs.

Communication is improving - but discipline is uneven

There is a clear increase in the use of visuals, summaries and more accessible formats.

Many companies are investing more in design, particularly at the front of the Sustainability Statement, using infographics, transition plans and summary pages to make content easier to navigate.

At the same time, some of the fundamentals are slipping.

Clear ESRS labelling and signposting - critical for navigation and comparability - is inconsistent, with fewer companies applying it effectively than in the previous cycle.

The result is a growing gap between communication and compliance.

Materiality and value chain disclosure are still evolving

Some of the most complex areas of CSRD remain a work in progress.

Fewer companies are using traditional materiality matrices, instead shifting towards more detailed tables of impacts, risks and opportunities. At the same time, value chain disclosures are becoming more visual, with companies mapping impacts across upstream, operations and downstream activities.

While this adds depth, it also introduces variation. Approaches differ not only in format, but in how clearly they explain scope, thresholds and methodology.

Sustainability is moving beyond the statement

Another notable shift is where sustainability is being communicated.

More companies are including sustainability content in the front end of the annual report - through highlights pages, summaries or integrated strategy sections - rather than relying solely on the Sustainability Statement.

This reflects a broader attempt to reach different audiences, including investors, employees and customers, and to position sustainability as part of overall performance rather than a standalone disclosure.

Comparability is becoming harder to maintain

Taken together, these changes point to a more complex picture.

Reports are becoming more usable and more tailored. But they are also becoming less consistent.

Different interpretations of ESRS requirements, combined standards, varying levels of disclosure and uneven assurance approaches are starting to create divergence across the market.

This matters because comparability is one of the core objectives of CSRD.

As companies move beyond compliance and begin shaping their own reporting approach, maintaining that comparability becomes more challenging.

From compliance to control

The shift from the first cycle to the second is less about meeting requirements - and more about how those requirements are applied.

Companies are beginning to take greater control over how their sustainability story is structured and communicated. The question is no longer just whether disclosures are complete, but whether they are clear, consistent and meaningful.

That creates a new balancing act: improving communication without losing the discipline that makes reporting usable and comparable.

Explore the full report

The CSRD: one year on report explores these trends in detail, with data, examples and practical recommendations drawn from the first 20 Sustainability Statements.

Got any questions?

If you’d like to discuss how these insights could help your organisation’s CSRD approach, we’d be happy to connect you with Black Sun Global’s Reporting & Disclosure team.