The CSRD represents a seismic shift in the regulatory landscape, situated at the intersection of geopolitics, economic transition, and stakeholder accountability. Since the EU Green Deal in 2019, companies have grappled with competing forces—like the fossil fuel resurgence post-Ukraine conflict, anti-ESG sentiment in the U.S., and ongoing decarbonisation efforts across Europe.
CSRD is fast becoming the cornerstone of corporate reporting, bringing coherence to the once overwhelming “alphabet soup” of standards.
The CSRD implementation timeline has recently been updated, and announced as part of the EU’s Omnibus package in May 2025:
These staggered phases offer breathing space—but also introduce complexity, particularly for multinationals operating across jurisdictions.
As organisations ascend the CSRD maturity ladder, they encounter a steep learning curve that demands comprehensive internal alignment across functions such as sustainability, finance, HR, investor relations, audit, and governance.
A key challenge lies in sourcing and integrating both qualitative and quantitative data to support robust and reliable disclosures. Structuring sustainability statements to be not only compliant but also meaningful is essential, as is ensuring interoperability with existing frameworks like ISSB and TCFD. Ultimately, CSRD is pushing companies beyond compliance, encouraging a more strategic, comparable, and forward-looking approach to sustainability reporting.
Early adopters of CSRD provide valuable insights for those preparing to report. Analysis of Wave 1 disclosures shows an average statement length of 66 pages, with 85% including images and 75% featuring infographics to enhance visual engagement. In terms of content, 30% incorporated case studies, though only 20% offered forward-looking information, highlighting a gap in future-oriented reporting.
Common trends included repetitive content around Impact, Risks, and Opportunities (IROs), inconsistent application of risk assessment methodologies, and limited explanation of the purpose behind Disclosure Requirements (DRs). Best practices emerging from these early reports emphasise the importance of clear structure and labelling, the use of value chain visuals to provide context, and stronger integration of forward-looking narratives.
CSRD does not operate in isolation, and the webinar highlighted the challenges of aligning it with other reporting frameworks. One key area of complexity is ISSB reporting, where uptake of IFRS S1 and S2 remains limited, and companies are still determining the most effective placement of this information within their corporate reports.
Meanwhile, approaches to sustainability reporting vary: some organisations have phased out standalone sustainability reports in favour of integrated disclosures, while others retain them to address broader communication goals beyond regulatory compliance. This has given rise to a dual-reporting model, where communication and compliance are treated as distinct yet complementary efforts—balancing strategic storytelling with the rigour of mandatory disclosure.
There is no single “correct” approach to CSRD reporting, but four broad models are emerging to suit different organisational needs. The All-in-One model integrates both CSRD compliance and robust sustainability narratives within the annual report. The Half & Half approach places compliance-focused content in the annual report, while a separate, lighter Sustainability Report highlights strategic messages.
In the Split model, full compliance is housed in the annual report, with broader, audience-friendly sustainability storytelling presented in a separate report. Lastly, the Private Company Model involves filing compliance documents discreetly with regulators, while using digital or corporate brochures to convey brand-aligned sustainability messaging. Ultimately, the choice of model should reflect a company’s strategy, audience, and reporting maturity.
Black Sun’s experts outlined a practical roadmap to guide organisations through their CSRD journey, regardless of their current stage. The first step is to assess scope and readiness—companies should not wait but instead use any additional time to refine their approach. Planning the narrative is equally important, including whether to prioritise CSRD or ISSB in sequencing disclosures.
Structuring the report strategically is key, with options ranging from organising around governance, risk, and strategy to using a materiality-topic-based format. Organisations must also tailor their messaging to meet the varied expectations of stakeholders such as investors, regulators, employees, and customers. Finally, maintaining flexibility is essential, as evolving guidance and emerging best practices will require companies to continuously adapt their reporting strategies.
The answer is nuanced. For Wave 1 reporters, it’s about refinement—balancing disclosure and communication, leveraging best practices, and evaluating stakeholder needs post-Sustainability Report phase-out. For Waves 2 and 3, the message is clear: Don’t wait. Start now. The extra time must be used proactively, not passively.
CSRD is not just a compliance exercise. It’s a strategic tool—helping organisations future-proof operations, earn trust, and create genuine impact. As Black Sun Global emphasised, this is a chance to redefine corporate storytelling with purpose and precision.
For further guidance or advisory support, reach out to: Anne Kirkeby, Investor and ESG Communications Director, Black Sun Global akirkeby@blacksun-global.com
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.
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