In our recent webinar, CSRD - One Year On, Anne Kirkeby, Investor & ESG Communications Director at Black Sun Global, explored how organisations are responding to CSRD one year into implementation, and how reporting approaches are evolving as companies balance regulatory disclosure requirements with the need for effective stakeholder communication.
Drawing on Black Sun Global’s latest research into CSRD sustainability statements, and building on last year’s analysis of the first 20 reports published, the session examined what has changed in year two, where best practice is emerging, and the challenges companies continue to face across Europe.
You can explore the research here: CSRD: One year on
Although the Omnibus proposals are still awaiting final approval, the reporting environment remains complex. While there has been a significant reduction in the number of qualitative and quantitative data points (around 61%) the overall structure of the sustainability statement remains largely unchanged.
As a result, the tension between communication and disclosure persists. Sustainability statements are highly disclosure‑driven by design, but they do not always meet the needs of broader stakeholder audiences seeking clarity, narrative and context.
At the same time, interoperability continues to present challenges, particularly for organisations scoped into both CSRD and ISSB reporting. Many companies are now navigating overlapping requirements and evolving international standards alongside CSRD implementation.
Despite these challenges, CSRD offers clear benefits. It establishes a common reporting language, improves comparability, focuses organisations on financially and impact‑material topics, and drives internal engagement and operational change. The question remains how best to communicate this information beyond regulatory audiences.
Last year Black Sun reviewed the first 20 CSRD sustainability statements published, all from Danish companies. This year’s research revisited the same cohort of companies analysed in year one, to understand how reporting approaches have changed between the first and second year of implementation.
The findings show that year‑two statements are shorter and sharper. Average length fell from 76 pages to 67 pages, with all but one company reducing their overall page count. Much of this reduction came from general disclosures, such as ESRS indices and EU datapoint tables being moved to the back of reports, as well as tighter, more concise language.
While these statements were already relatively short by European standards, best‑in‑class reporters have gone further by making clearer distinctions between disclosure‑heavy sections and more communicative content, rather than interweaving the two throughout the report.
Across the sample, all companies reported on E1 and S1, with only one company not reporting fully on G1, instead covering elements of it as an entity‑specific standard.
While headline averages suggest little change year‑on‑year, a deeper review shows movement beneath the surface. In some cases, companies dropped certain topical standards while others added them. However, when changes occurred, explanations were often limited, making it harder for readers to understand the rationale behind shifts in scope.
In a small number of cases, companies combined two environmental standards where there was significant overlap in policies and actions, reducing repetition and improving clarity.
One of the most striking findings this year was how companies are beginning to test the flexibility of the CSRD framework. Several different structural approaches emerged:
These approaches create a clear boundaries between communicative content and regulatory disclosures, making the reports easier to navigate while allowing key pages to be reused across wider stakeholder communications.
Many companies introduced additional communicative elements, including case studies, visualised transition plans, value chain diagrams, infographics and navigation side panels summarising policies, actions and targets.
There has also been a noticeable shift away from traditional materiality matrices. Instead, companies are using detailed IRO tables and value chain mapping, often providing richer insight into impacts, risks and opportunities across time horizons and business activities.
These IRO disclosures are increasingly positioned within topical standards rather than only in general disclosures, improving alignment between narrative and data.
The research also explored how sustainability content appears elsewhere in annual reports. While the sustainability statement remains the primary location for disclosure, many companies continue to include high‑level sustainability content elsewhere, such as performance highlights and strategy discussions, at a more communicative level.
This reflects an emerging pattern: disclosure remains anchored in the sustainability statement, while storytelling and engagement increasingly sit either at the front of the annual report or within strategic sections.
The findings also highlight significant regional variation. Danish and broader Scandinavian reports tend to prioritise conciseness and usability, while other European markets favour more comprehensive, disclosure‑dense approaches, often influenced by differing assurance practices.
Black Sun Global supports organisations at every stage of their CSRD journey - helping align regulation, reporting and communication to meet both compliance requirements and stakeholder expectations.
Our team advises on reporting structure, sustainability strategy, stakeholder communication and digital delivery, ensuring sustainability statements are robust, navigable and effective beyond regulatory audiences.
If you would like to discuss the findings from this webinar, receive the full recording, or explore how we can support your CSRD reporting approach, please contact:
Bob Crosbie-Dawson, Head of Business Development
BCrosbie-Dawson@blacksun-global.com
About Black Sun
Black Sun Global is a stakeholder advisory and engagement agency that's been driving transformation and positive change for ambitious brands for more than 20 years. With deep expertise in disclosure and reporting, ESG, sustainability, and digital engagement, we reshape how organisations connect with customers, investors, employees, and the wider world.
We are trusted partners to some of the most influential global organisations, sparking innovation and sustainable performance through our strategic insights, partnerships, and proprietary technologies.
As founders of the Positive Change Group, we are on a mission to create a new kind of stakeholder relations partner. Our world-class specialists work closely with executive leadership teams to protect reputations, inspire trust, and promote responsible business practices - building resilience and long-term value in a rapidly changing world.
For more information, please visit: www.blacksun-global.com
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