Assessing the Components of a “Good” CSRD Report

2025-10-23

Emilie Jones | Senior Sustainability Consultant

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As Japanese companies begin preparing CSRD-aligned reports we are frequently asked how companies can ensure their reports can be viewed as credible compared to industry peers. To answer these questions, we have assessed published reports to prepare a case study for 5 CSRD reports from various industries to give concrete examples of what “good” and “poor” reports include.

Context and Background

Risk, reward, business continuity – there are many reasons for corporate sustainability but the most universal is compliance. The European Union’s CSRD reporting requirements expand mandatory sustainability reporting beyond companies established in the EU to include corporations with significant business operations therein.

(For more information about what companies will need to report and when, please read our previous article on CSRD reporting, including changes from the Stop the Clock directive.)

Despite required reporting being delayed for most entities, many corporations have already begun issuing CSRD-aligned or CSRD-targeting reports. Various firms including EY, Deloitte & DRSC, Key ESG, etc have issued English language broad spanning analyses of the first CSRD reports but give few specific actions for how companies can leverage learnings from early movers to leapfrog in their reporting quality. In this article, we will summarize their findings and provide analysis of selected reports targeted towards Japanese reporting entities looking to prepare for their own FY 2026 or 2027 issuance.

Initial CSRD Report Demographics

Before discussing the components of an ideal CSRD report, let us look at commonly asked questions regarding the demographics of the reports issued so far by answering some frequently asked questions.

Who is reporting?

Those who had already been reporting from 2023.
Those who have securities listed on the EU-regulated market.
Early movers who recognize the expanded CSRD data needs and wish to test their reporting systems in a low-risk environment before being subject to mandatory reporting requirements.

How many corporations have published CSRD reports so far?

Over 250 CSRD-aligned reports have been published, with more companies expected to publicly report next year.

Are non-EU companies reporting?

Some are reporting as first movers.
Some are reporting as they have listed securities on the EU-regulated market.
Some companies are issuing “towards CSRD compliance” reports with the acknowledgement that their sustainability report intends to align to CSRD reporting in the future, and has begun to incorporate such elements, but is not currently fully CSRD aligned.

How long are the reports?

Report lengths range significantly depending upon the extent of integration a company has undertaken. If a company has integrated their financial and ESG reports entirely, the reports are often over 400 pages.
The sustainability contents of reports for most companies, however, average 100-200 pages.
The extensive length is in part due to the expanded reporting requirements under CSRD but is also a result of larger companies being required to begin issuing reports first. As smaller companies with less complex organizational structures begin issuing reports, the average length of reports is expected to fall slightly.

What is included? What is not?

Most reports are aligned to multiple reporting frameworks, both regional like CSRD and international like ISSB.
Risk and opportunity analyses are universally included in all reports but do not follow a consistent methodology. Some reports combine corporate risk and opportunity analyses with impact assessments based on material CSRD metrics. Others strictly separate corporate R/O(Risk/Opportunity) assessments from CSRD impact reporting.
Double materiality, a requirement of CSRD, is included in each report, but the quality of assessment varies greatly. The more robust reports include step-by-step descriptions of assessment methodologies and pinpointing of the materiality point within the supply chain.

How to have a “good” report?

Organization

A report should be designed to be read. Investors, regulators, and NGOs should be able to find the information they need with relative ease. Strong report organization enhances the credibility of the report overall as readers are easily able to identify what is and is not included, where data references for stated claims can be made, and to which reporting standard(s) a data point aligns. If a section references data already presented elsewhere, include the section where that data can be found such that readers can easily have context for your conclusions even if they do not read the entire report.

Best practices include using tags to indicate which sections respond to CSRD reporting requirements and color coding sections to indicate which ESRS a section answers. L’Oreal’s 2024 Universal Registration Document provides an example of using tags to indicate which sections respond to CSRD and which comply with the Annual Financial Report (AFR) metrics. Lotte uses colored bullet points in their 2024 Sustainability Report to indicate environmental, social, or governance related topics.

Be clear, be consistent

The best reports were not the longest, but the most direct in their responses to reporting details. Rather than diluting the important information with superfluous detail and vague statements, directly identify the reporting metric and the response. If a company would like to add nuance, case studies, or other supporting content to their report, they should highlight the reported metric first, then follow up with any additional information. Show, don’t tell is an old adage in writing classes that means to use concrete data and examples to show a reader what you have done, rather than telling them about it. Rather than say “relevant stakeholders were consulted”, list the stakeholder groups that were consulted and how.

Best practices range widely depending upon the topic of discussion. Stakeholder engagement can be disclosed by detailing the group, how they are relevant, and the means of engagement. For conglomerate groups, best practices can include presenting quantitative or bulleted group wide information on one side of the page, with supporting examples from subsidiaries included to the other side. LOTTE Corporation’s 2024 sustainability report is structured in this way.

Be honest

If you cannot include something or need to use an assumption due to lack of data or sensitivity of the information, make that clear. It lends credibility to the information that is reported. The best reports not only identified data gaps but outlined plans and timelines for filling those gaps.

Best practices include defining the assumptions used in generating a methodology, in particular quantitative ones, and clearly acknowledging any ongoing methodology development work. Ford Motor Company’s 2024 Integrated Sustainability and Financial Report provides an example of this open approach to disclosure.

Well Defined Methodologies

Clearly defining the methodologies used to make risk and opportunity assessments, materiality assessments, GHG inventory analysis, etc allows current and potential investors to understand how the quantitative analyses are derived, reducing skepticism and uncertainty. Follow the above 3 tips on organization, clarity, and honesty. It is okay for a methodology to be in review. Many of the metrics being reported on are new to companies. Data gaps and assumptions are to be expected. But a company that does not acknowledge their weaknesses is unlikely to be reliably reporting their strengths.

Best practices include detailing the step-by-step process used to conduct any analysis, who were involved and at what level, and whether the assessment was validated – by whom, internal or external, and the level of assurance. Ford’s detailing of their human rights saliency assessment’s process and mechanisms as well as the international guidelines upon which it is based and L’Oréal’s DMA reporting which includes a step-by-step description of the methodology process as well as each level of validation it underwent can be examples of this.

CSRD Reports Case Study: Which reports should Japanese companies reference?

We selected 5 companies from disparate industries to review their CSRD reports in detail. These corporations operate in some of the markets in which Japanese companies are competitive and may be your industry peers. They represent both European companies and international companies reporting to international standards. Of particular interest to Japanese companies may be Lotte, a Korean conglomerate similar in structure to many large Japanese corporations, and Ford, a major player in the automobile industry that is also reporting as a non-EU company.

The above is a small snapshot of the CSRD reports already issued. Codo Advisory can support your company in benchmarking the CSRD and ESG reporting of your industry peers, giving you confidence in what you publish. Contact us to learn more about our CSRD and ESG reporting advisory services.

Sources and Additional Information

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