Two years of CSRD: what reporting maturity really looks like
The first wave of CSRD sustainability statements landed in 2024. The second has now followed. With two reporting cycles complete, it is now possible to read CSRD not as a snapshot, but as a trend line.
We reviewed the first wave of year-two sustainability statements across European organisations spanning renewable energy, wind manufacturing, beverages, financial services, staffing, IT services and regional banking.
This review reflects reporting prior to the full impact of the EU’s proposed CSRD omnibus reforms. While scope and timelines may evolve, the patterns emerging between year one and year two are already clear. Regulatory simplification may adjust the perimeter. It will not remove the expectation for credible, decision-useful sustainability information.
Here is what year two is beginning to reveal.
Reports are getting shorter
Across the seven sectors, sustainability statements were shorter in 2025 than in 2024.
Excluding beverages, sustainability statements were on average 16 pages shorter year on year, with reductions observed across all other organisations reviewed.
This is not a sign of reduced ambition. It is a sign of improved judgement.
Year-one reports were often padded with explanatory scaffolding. Organisations repeated ESRS requirements, expanded methodology sections, and layered caveats around disclosures. In year two, many have removed this defensive framing and allowed the data and decisions to stand on their own.
Shorter reports signal confidence when substance remains intact.
Double materiality is maturing
In 2024, DMA was largely a first-time exercise. In 2025, most organisations explicitly re-ran the assessment.
Across the cohort, year-two changes were less about new issues emerging and more about organisations becoming more precise about what is truly material. For example, one company removed four sub-topics after applying a more granular ratings methodology. Another reduced total material IROs from 40 to 31 by eliminating redundancy rather than substance.
In these cases, shorter materiality lists reflect stronger analysis.
What is improving is the clarity of materiality assessment criteria and thresholds. Organisations are applying more defined scoring methodologies to impact and financial materiality, leading to tighter and more defensible outcomes.
Climate is being tested against reality
The clearest sign of E1 maturity in year two is not stronger ambition. It is stronger progress tracking, and a growing willingness to report when trajectory is not on course.
In 2024, climate disclosures were largely structured around target setting, including net-zero commitments, interim milestones, and SBTi status. In 2025, stronger reports move from stating what is intended to reporting what is happening. Decarbonisation levers are described with clearer links to capex and opex. Some organisations explicitly acknowledge that interim targets will not be met, explaining why and what is changing.
That honesty matters. A framework that rewards ambition encourages target setting. A framework that rewards accurate progress reporting, including shortfalls, creates decision-useful disclosure. Year two is beginning to reveal which organisations are moving in that direction.
Workforce reporting is more analytical
S1 disclosures are moving beyond policy inventories. In year two, the strongest examples explain reasoning, trade-offs, and structural constraints rather than simply listing metrics.
Where single headline figures are presented, the better reports explain why those figures may be misleading without context. Pay-gap disclosures, for instance, increasingly acknowledge that the number alone tells an incomplete story when compensation is driven by role type, sector of placement, or organisational structure.
New workforce policies are appearing in 2025 reports that were not present in 2024, introduced directly in response to findings from employee engagement processes. When disclosure creates organisational change, the framework is working as intended.
Governance is showing operational depth
In 2024, governance sections largely documented that policies exist. In 2025, the stronger reports show how governance actually functions.
The difference is between stating that ESG risk assessments are performed and describing the systems, processes, and decision points through which those assessments shape business behaviour. Governance disclosure is shifting from documentation to operational evidence.
The weak spots have not moved far
Biodiversity. E4 disclosure has not materially advanced between years. The explanation is methodological. Unlike climate reporting, biodiversity lacks widely adopted, sector-neutral quantification standards. Until measurement infrastructure matures, reporting will remain uneven.
Transition plans. Nearly every sector has articulated a net-zero ambition. Fewer demonstrate credible execution pathways. Capital allocation is rarely linked clearly to decarbonisation commitments. Interim pathway tracking remains limited. Financial-statement assumptions are seldom stress-tested against climate scenarios.
The gap is not between ambition and intent. It is between stating a destination and demonstrating the route.
What this means
Two years of CSRD reporting reveal clear maturity markers.
Leading organisations:
- re-run and refine DMA annually
- tighten materiality lists rather than expanding them
- link targets to capital allocation
- disclose limitations transparently
- reduce volume while increasing analytical depth
Less mature organisations continue to treat CSRD as just a report.
Regulation may change. Investor scrutiny and stakeholder expectations will not. Organisations that embed sustainability into financial planning, procurement, risk management, and workforce strategy will remain differentiated regardless of regulatory simplification.
How Luminous can help
At Luminous, we support organisations that want to use CSRD as a strategic management tool rather than a reporting obligation.
If you are preparing for your next reporting cycle, re-running materiality, strengthening a transition plan, or reassessing your approach in light of the omnibus reforms, we would welcome a conversation.
