Comparing x8 CSRD Reports from all the major audit firms

As more and more CSRD articles get published, I have decided to assess a new batch of reporting. This week I have looked at the following x8 reports. To note, I decided to look at x2 reports that were audited by each of the big 4 auditors. 

This articles goes into findings from each of these companies: 

First, a list the companies we assessed and what topics they found material. 

• BBVA (EY) X4 Material Topic Standards: Climate Change, Own Workforce, Consumers and End Users, Business Conduct. ‍
• Kone (EY) X5 Material Topic Standards: Climate Change, Own Workforce, Workers in the Value Chain, Consumers and End Users, Business Conduct.‍
• Randstad (Deloitte) Unable to determine number of ESRS topic standards. 9 material topics. E1 Determined not Material: As this topic was not considered material, we do not disclose material impacts and risks with respect to climate change and therefore omit disclosures required per ESRS E1 Climate Change.Used language outside of ESRS for their materiality assessment results. ‍
• Vestas (Deloitte) X8 Material Topic Standards: E1 Climate Change, E3 Water and Marine Resources, E4 Biodiversity and Ecosystems, E5 Circular Economy and Resource Use, S1 Own Workforce, S2 Workers in the Value Chain, S3 Affected Communities, G1 Business Conduct‍‍
• ‍With Secure (PwC) X4 Material Topic Standards: E1 Climate change, S1 Own workforce, S4 Consumers and end-user, G1 Business conduct ‍
• Stora Enso (PwC) X9 Material Topic Standards: E1 Climate Change, E2 Pollution, E3 Water and Marine Resources, E4 Biodiversity and Ecosystems, E5 Resource Use and Circular Economy, S1 Own Workforce, S2 Workers in the Value Chain, S3 Effected Communities, G1 Business Conduct‍
• MAPFRE (KPMG) X5 Material Topic Standards: E1 Climate Change, Own Workforce, Workers in the Value Chain, Consumers and End Users, G1 Business Conduct. Note: Somewhat difficult to determine material topics. ‍
• Norsk Hydro (KPMG) X9 Material topics: Climate Change, Pollution, Water, Biodiversity, Resource Use and Circular Economy, Own Workforce, Workers in the Value Chain, Affected Communities, Business Conduct. 

Summary of findings:

Based on the analysis, Vestas is the best overall report from this group. 

What should be a goal of an ESRS report: While compliance is a requirement, from a goal perspective we assessed reports on: Do they make it easy to compare sustainability topic performance versus another company.

Why was Vestas the best: From the second you open their Appendix you can tell it is going to be a clean, easy to read report. Their “Sustainability Statement” on page 2 already brakes down all of their material topics and even offers helpful hyperlinks to the correct pages. Expanding from that, each topic standard follows a consistent structure and provides many ESRS codes as reference throughout the review. To round it off, tables are effectively used to summarise their data versus ESRS requirements. 

Best in class attributes:

1. Use ESRS codes everywhere possible
2. Follow the ESRS structure and language
3. Provide an index table by disclosure point
4. Show what topics are not material in a table
5. Publish tables communicating your company IROs
6. Structure your report material category sections following ESRS requirements
7. Publish a table of stakeholder engagement

Some things that didn’t work: 

• Not leveraging ESRS codes: It is MUCH harder to look at a report that doesn’t leverage the regulatory codes. It is even harder if they use their own material topic language outside the regulation. 
• Companies who haven’t restructured their appendix: A number of companies have re-structured all their sustainability information to align with ESRS. Those who haven’t have much clunkier ESRS sections overall. 

Audit form choice: Which audit firm was used seemed to make no impact on quality of report structure. My assumption is it is individuals within each of these companies who led to the overall format that has been published. 

Total Material topics: The fewest material topics was 4, the highest was 9. 

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BBVA: 

CSRD not in Spanish Law: In BBVA report they mention choices made are impacted because CSRD is not transposed into Spanish law, thus disclosure is done in reference:

“It should also be noted that a new regulatory framework regarding the publication of corporate sustainability information has come into force in the European Union: Directive 2013/34/EU, as amended by Directive (EU) 2022/2464 (hereinafter, the “CSRD”), and Delegated Regulation (EU) 2023/2772, which specifically develops the common standards for sustainability reporting (hereinafter, ESRS - European Sustainability Reporting Standards). The CSRD had not been transposed into Spanish law as of December 31, 2024.”

“BBVA publishes non-financial information by considering the regulatory framework in force in Spain as of December 31, 2024, using the new ESRS regulatory framework as a reference.”

Unlike some of the Danish companies CSRD reports we looked at, BBVA does not follow language from the ESRS topic standards as precisely as other companies. Their appendix does use CSRD language, but the coding is different overall. 

BBVA determines for x4 of the 10 topic standards to be material. 

IRO Disclosure is further broken down into a table. 

‍

KONE: 

In the case of KONE their Sustainability Statement is published separately from financial information. Kone’s report structure overall aligns very closely to the ESRS requirements. 

For their DMA disclosure, they breakdown in a table what stakeholders were engaged with and how. 

They further expanded their DMA to show materiality of all of the topic standards assessed. 

When disclosing about policies they published helpful tables indicating who is responsible for what as well as coverage.

Randstad: 

Prepared in accordance with IFRS and CSRD: “The financial statements have been prepared in accordance with the International Financial Reporting Standards (IFRS) as adopted by the EU.The sustainability statements have been prepared in accordance with the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) issued by the European Financial Reporting Advisory Group (EFRAG).”

Who provided input to their DMA:

To ensure the accuracy and relevance of our materiality assessment, Randstad actively sought external validation from a diverse group of affected stakeholders. This process involved engaging directly with stakeholders through surveys, distributed to the following groups: •

• 2,000 corporate employees 
• 20,000 talent across our top ten markets
• 2,000 clients in our top ten markets  
• Key industry stakeholders, including IOE, VBDO, and the UN Global Compact

The feedback received affirmed the completeness and accuracy of our material topic listing. Across all stakeholder groups,the most criticaltopics identified were working conditions, diversity and occupational health and safety (OH&S). When analyzing the results by stakeholder group, the following material topics emerged as priorities: 

• Corporate employees: Working conditions, diversity, OH&S 
• Talent: Working conditions, OH&S, upskilling and reskilling 
• Clients: diversity, working conditions, business ethics 
• Industry stakeholders: diversity, working conditions, upskilling and reskilling

DMA results did not use ESRS language:

The nine key material topics have been mapped with the top risks identified from our risk & opportunity management process. Top risks (e.g., talent management, workplace health and safety, and IT & security, data protection) are risks that are linked to the key material topics. The risk mitigation for the top risks are disclosed in the risk and opportunity management section. For each of these key material topics, we have disclosed the relevant policies, actions and targets in the specific Environmental, Social and Governance sections. Specifically in regards to data security and privacy, this is listed separately in the image below due to the different outcomes for talent vs. corporate employees, however, we have chosen to disclose relevant information in the Governance section as this is managed centrally. The outcome of these actions are purposely designed to address the risks and opportunities specific to the key material topic, and stakeholders input was considered when setting relevant. 

List of their 9 material topics below: 

IRO communication: Similar to BBVA, their IRO are broken down in a table. 

Randstad includes a section they label “Non ESRS Disclosure” to provide disclosure on additional topics. 

Vestas

Structure: Their structure completely mirrors the ESRS requirements. This follows best in class we have seen from other ESRS report comparisons. 

Follows an IRO table structure that we are starting to see repeated between ESRS reports. 

Furthermore they offer ESRS codes throughout their disclosure: 

Even quantitative tables include ESRS metrics needed.

Finally they follow an index table report at the end of their report helping readers identify where disclosure exists. 

WithSecure

Disclosure requirements were broken down to say what is and is not material. 

Like many of the other reports they also communicate how stakeholders were engaged. 

IRO Tables are published to understand specific material topics:

Stora Enso

Detailed tables helping companies find their ESRS disclosure:

Furthermore they have a table to show what is and is not material: 

They also publish IRO tables and show codes by every section of disclosure: 

MAPFRE

Harder to find overall their material topics and ESRS disclosure overall. Breaks down material issues by Positive Impacts, Negative Impacts, Risk and Opportunities. 

They provide a table of where to find information overall: 

Hyrdo

In compliance with CSRD and Norweigian law: “Hydro’s sustainability statements are prepared in compliance with the EU Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), the Norwegian Accounting Act, and other applicable regulations.”

Provides short narrative text around their material topics: 

 A human readable “Why it matters” section by each material topic: 

Water: Why it matters: “Hydro depends on the supply of water as an ecosystem service and withdraws large volumes of water for beneficiation and pumping at its Paragominas mining operations, steam generation in the Bayer process at the Alunorte alumina refinery, and for cooling and operations in Hydro’s primary aluminium and recycling processes. Freshwater withdrawals can have a negative impact on local water resources in the event of drought.”

Each section showcases Reporting Principles:

Detailed table at the end of their report showcasing where disclosure standard information sits: 

Want to work with Nossa Data to streamline your CSRD reporting? Get in touch at solutions@nossadata.com