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The First ESRS Compliant Reports: Examples from Denmark

As the first FY2024 compliant reports begin to get published, at Nossa Data we want to highlight and educate the market about what we are seeing. This article will show examples of x3 ESRS reports from Denmark we have seen published as of February 2024. 

Who has published reports already and that are they called: 

1. Tryg: Annual Report 2024. A Scandinavian insurance company. 

2. Net Company: Annual Report 2024. A Danish IT consultancy. 

3. DSV: Annual Report 2024: Danish Transport and Logistics firm. 

What were the above company ESG ratings as of February 2025? 

Tryg: Sustainalytics: 19.0, MSCI: AAA

Net Company: Sustainalytics: 13.4, MSCI: A

DSV: Sustainalytics: 12.9, MSCI: AA

How do FY 2023 to FY 2024 reports compare? Looking at Tryg and DSV, both reports got 30 pages longer and their sustainability section was completely re-arranged to align with ESRS requirements. 

  • Tryg: In 2023 their annual report was 190 pages, their FY 24 report was 221 pages. Meanwhile, in 2023 their Sustainability Report aligned targets to the SDGs, the 2024 report no longer mentions SDGs.
No longer reference the SDGs in FY24
  • DSV:  Their 2023 annual report was 106 pages, the 2024 one was 159 pages. Structure for sustainability information changed completely from a combined financial / non-financial information section in 2023 to in 2024 mirror the ESRS formatting. E.g.:
    • Sustainability statement 
    • Double materiality assessment
    • Basis for preparation 
    • Environmental information 
    • Social information 
    • Governance information

While best practice of ESRS reports is still being defined, we see examples within these three reports we believe it would be wise for other companies to mirror. ESRS Disclosure Index embedded within your report: All three companies published an index of their material disclosures and allow you to reference the page numbers of where specific ESRS aligned disclosures can be found. Tryg and NetCompany put these indexes in the middle of their report while DSV reference table is at the end. Tryg Example: 

Hyperlinks to correct page

Net Company Example

Reference table at start of sustainability section

DSV Example

At the end of their report a reference table

EFRAG Data Points in Disclosure: Tryg used the EFRAG Data point codes within their reporting to showcase specific data point level disclosure. Data point names (EFRAG vs Tryg disclosure - e.g. ESRS ID)

EFRAG Data Points
Matched data points in Tryg disclosure

How did they communicate the results of their DMA? All three of the companies who we looked at published a graphic which indicated the ESRS topic standards and which are material to their organisation. See examples below: Tryg DMA Image

Labeled under ESRS

Net Company used check marks to indicate material topics. 

Used check marks to indicated materiality

DSV used a matrix to communicate

Broke down materiality in a table

What can other companies learn from these early examples:

First of all, sustainability sections of annual reports need to be completely restructured from past reporting cycles to align with ESRS disclosures. 2. Use ESRS langauge and ideally reference exactly where each indicator is disclosed. While only Tryg mentioned exact EFRAG data points we expect more companies to follow this practice as additoinal reports get published.

Want to prepare your ESRS disclosure with Nossa Data? We love working with corporates on all aspects of ESG disclosure. If you would like to get in touch around how we work with listed companies, contact solutions@nossadata.com

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