How Companies Are Responding to the CSRD: Evidence from Early Sustainability Reports
Findings highlight heterogeneity in materiality assessment methodologies, a strong emphasis on negative impacts/risks over positive impacts/opportunity disclosure, and the systematic underreporting of certain ESRS standards. A working paper by Francesca Collevecchio
This Working Paper was prepared for the IEP@BU–SDA Bocconi event Sustainability Disclosure: Red Tape or Strategic Tool for the Future of Business? held on June 24, 2025.
Executive Summary
The Corporate Sustainability Reporting Directive (CSRD) marks a pivotal transformation in the European Union’s sustainability disclosure landscape, mandating the adoption of standardized reporting through the European Sustainability Reporting Standards (ESRS) and the implementation of the double materiality principle.
While scholarly attention has largely focused on the legal design and normative ambitions of the directive, empirical research on its implementation remains scarce.
This paper presents a qualitative analysis of the first sustainability reports published under the CSRD by a purposive sample of ten large companies based in Italy and France.
By conducting an in-depth examination of disclosed Impacts, Risks, and Opportunities (IROs), the study offers preliminary insights into how companies are interpreting and applying the new requirements.
Findings highlight heterogeneity in materiality assessment methodologies, a strong emphasis on negative impacts/risks over positive impacts/opportunity disclosure, and the systematic underreporting of certain ESRS standards – particularly those related to value chain and community impacts (S2 and S3).
Social disclosures, in particular, tend to reflect a retrospective and reputational logic, with limited integration of forward-looking or systemic impact considerations.
These findings highlight critical gaps between regulatory ambition and organizational practice, underscoring the need for enhanced methodological guidance and capacity-building efforts to fully realize the directive’s transformative potential.
IEP@BU does not express opinions of its own. The opinions expressed in this publication are those of the authors. Any errors or omissions are the responsibility of the authors.
