EFRAG has published the State of Play 2025 Report, an in-depth analysis of the first wave of ESG disclosures in line with the European Sustainability Reporting Standards (ESRS). The study is based on sustainability reports published by 656 companies by 20 April 2025, in compliance with the Corporate Sustainability Reporting Directive (CSRD). While non-binding, the report offers a highly indicative overview of how companies are implementing the new European standards.
Length and structure of reports
The average report length is 115 pages, with significant variations across sectors and countries. Companies in Southern Europe – particularly Italy and Spain – produce longer reports, often influenced by traditional accounting practices. Financial institutions (FIs) tend to issue even longer reports due to the complexity of EU taxonomy disclosures.
Materiality: what really matters
Only 10% of companies consider all 10 topical standards to be material. Three themes dominate most reports:
- ESRS E1 – Climate change (98%)
- ESRS S1 – Own workforce (99%)
- ESRS G1 – Business conduct (93%)
In contrast, topics such as biodiversity, microplastics, and the rights of Indigenous peoples remain marginal. Interestingly, non-financial companies tend to identify more material topics on average than financial ones.
Stakeholder engagement and double materiality
97% of reporting entities involve internal stakeholders in their double materiality assessment, but only one third engage with NGOs or local communities. EFRAG stresses the need for broader and more representative stakeholder engagement, also to prevent reputational risk and greenwashing.
Climate transition plans: work in progress
55% of companies report having a climate transition plan, but only a minority provide details consistent with Implementation Guidance IG4. Less than half include Scope 3 emissions in their targets. However, there is a growing adoption of SBTi-validated targets, indicating a shift toward greater rigor.
Carbon pricing and biodiversity lag behind
Only 20% of companies apply an internal carbon price, mainly in the mining, energy, and transport sectors. Biodiversity metrics appear in just 30% of reports, and often in unstructured formats. The most advanced sectors are construction, energy, and real estate.
Human rights and workforce
93% of companies declare they ensure adequate pay, but with little distinction between EEA countries and third countries. Serious human rights incidents are rarely reported: only 5% of preparers disclose actual cases, highlighting possible transparency gaps.
Conclusions
The first ESRS reporting cycle shows a promising but still uneven landscape. Companies are beginning to familiarize themselves with the new regulatory architecture, but gaps remain in terms of transparency, data granularity, and integration. Through this report, EFRAG provides an important empirical basis to guide future developments in regulation and corporate practice.
