AI Comparison of Pre and Post CSRD Reporting: Maersk, Orsted, Novo Nordisk

This article focus on changes to ESG reporting from x3 companies in FY23 versus FY24. At Nossa Data, we focus a lot of time understanding how AI readable are corporate ESG reports and understanding what topics companies do and do not disclose. For this exercise we have looked into the following reports: 

• Maersk FY24 Annual Report (Claim full CSRD Compliance audited by PWC) v Maersk FY23 Annual Report
• Orsted FY24 Annual Report (Claim full CSRD Compliance audited by PWC) v Orsted FY23 Annual Report (CSRD aligned)
• Novo Nordisk FY24 Annual Report (Claim full CSRD Compliance audited by Deloitte) v Novo Nordisk FY 23 Annual Report‍

‍If you are interested in learning more about how Nossa Data uses AI to streamline listed company disclosure, please get in touch. ‍‍

How do the reports compare? ‍

All three companies have significantly longer reports

Maersk: 127 pages to 204 pages
‍Orsted: 252 pages to 258 pages (smallest increase likely because they did voluntary ESRS disclosure in FY23)
‍Novo Nordisk: 112 pages to 152 pages. 

All three reports spent more time discussing ESG in 2023 than 2024.

Nossa Data’s AI can assess what % of a report is concentrated on specifically ESG terms. All three companies saw a significant % increase. 

Maersk: 5.2% of their 2023 report was about ESG versus 9.4% of their 2024 report.
Orsted: 8.9% of their 2023 report was about ESG versus 11.1% of their 2024 report. 
‍Novo Nordisk: 6.3% of their 2023 report was about ESG versus 9.93%. 

Changes in thematic areas of ESG Disclosurees

Many ESRS topics exploded in growth in companies disclosure. The following topics all were mentioned 50 additional times by the three companies in 2024 versus 2023. 

‍Emissions, ESRS, Value chain, Risk, Climate, Corporate Governance, Governance, Taxonomy, Health, Engagement, Renewable, Human Rights, S1, Energy, E1

Meanwhile, the following terms saw a collective drop in disclosure (but were still mentioned both cycles). Note the ESG frameworks seeing significant drops.

Natural Gas, TCFD, Net Zero, CDP, nomination committee, Biomass, Protected Areas, GHG intensity, GRI, Sustainability Committee, Breaches

All three companies did heavy mentions of the ESRS coding within their report. 

ESRS Code: Average mentions of code by company

S1: 68 mentions

E1: 67 mentions

G1: 25 mentions

Reports were restructured

Following trends we saw in the article I published earlier this week on Danish companies ESRS disclosure, including tables are very prominent. Orsted fundamentally from a structure position now has their sustainability disclosure align to ESRS. (FY24 report below)

Novo Nordisk chose to follow almost an identical structure (I had to double check I was looking at the right report!)

Maersk leverages EFRAG ID’s in their disclosure. 

Significant restatements of ESG data

Both Maersk and Novo Nordisk re-stated a number of figures from 2022 and 2023. 

‍Maersk said:
“We have made a number of other restatements to the 2023 numbers owing to improvement of reporting processes and data quality. Most notably, we made a correction to scope 1 emissions, as refrigerant emissions had been overstated in 2023. The correction has led to a restatement of scope 1 emissions of 1.7m tonnes CO2e or approximately a 5% reduction of total scope 1 emissions for 2023.” (Page 55)

‍Novo Nordisk said: “Changes in preparation, presentation or due to specific circumstances Restatements of historical data due to reporting errors in previous periods, and/or changes to accounting policies, are only performed if the materiality threshold defined in our restatement guidelines is exceeded. Management provides the specific disclosures required by CSRD unless the information is not applicable or is considered immaterial to the decision-making of the primary users of the Sustainability statement. Restatements are primarily due to improvements in calculation methodology or new scientific evidence as we continuously work to improve the accuracy of our sustainability reporting. In 2024, the organisational scope of some metrics was expanded to include all entities, but this has not resulted in any restatements.”

ESRS Index Tables are Key

Finally, we see ESRS index tables in all three companies disclosures. Orsted offers a great table showing their disclosure via data point and even lines it up to other regulation. 

Maersk discloses by disclosure point. 

Novo Nordisk references ESRS Disclosure standard by page number. 

‍If you are interested in learning more about how Nossa Data uses AI to streamline listed company disclosure, please get in touch to schedule an intro call.