Big 4: CSRD FY 2024 Analysis

May 29, 2025

With the majority of FY 2024 CSRD reports on the market, I decided to have a look at what the Big 4 Audit firms have been saying. I have previously analyzed CSRD reports from each of the audit firms. In light of the Omnibus, we do expect there to be a significant amount of revisions in the regulation (CSRD revision timelines available here). This article will look at what each of the Big 4 firms are saying around CSRD.

All 4 firms have already published an analysis of FY 24 CSRD.

EY: Published the EU CSRD Barometer 2025

KPMG: Published the Real-time ESRS Fast 50

Deloitte: I found region publication from Finland and Denmark

PwC: Published Insights from the first 100 CSRD reports

The below article dives into key learnings from each of these ESG reports.

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Who did each firm assess:

EY: CSRD-compliant reports released for the fiscal year 2024 based on a sample size of 200 companies
KPMG: Sustainability Statements of 50 companies that reported under ESRS in January and February 2025.
Deloitte: 35 Danish Large Cap Companies and 22 large Finnish listed entities.
PwC: First 100 published CSRD reports.

What are the key findings from each firm:

EY: Clear structure of the sustainability statement and linkage to ESRS topics and subtopics. They also noted that “Most companies have integrated their sustainability strategy into their overall business vision, strategy or model, stakeholder engagement was reported by all companies, 81% of companies utilized phased-in options to omit specific disclosure requirements. EY also offers analysis of the sub topics chosen by companies (e.g. what was disclosed within the topic standards)
KPMG: Noted a wide variety and quantity and how companies reported their IROs. They also noted IROs were focused in E1, S1, S2 and G1. They also commented that many companies forgot about AI when preparing their ESRS statements favoring visualisations over machine readability (Nossa Data agrees)
Deloitte: (Danish) This analysis focused on breaking down data point performance across topics such as board diversity, variable remuneration, employees and more. (Finnish) this report commented that all companies reported E1 and S1 as material. G1 was chosen by 21 of the 22 companies assessed. Deloite found that Climate change mitigation is the most universally chosen IRO.
PwC: Noted many companies were choosing to publish CSRD reports even if they were from countries that have not yet transposed the CSRD to law (Germany, Spain, Netherlands). They also noted a high degree of variability in how companies carried out the double materiality assessment.

Average Length of a Sustainability Statement: All of the reports commented on length with different figures depending on the batch of company reports they assessed. Overall it seemed that the average length of a Sustainability Statement was 70-80 pages total. Sectors with the highest average number of pages are Financial Services, 147 pages, Infrastructure, 139 pages, Transportation, 125 pages.

What topic standards were chosen: Nearly all companies (above 95%) chose E1, S1 and G1. The next most commonly chosen topic standards were S2: Workers in the Value Chain and E5: Resource use and circular economy.

Number of IROs that companies pick: Multiple of the analysis commented that there was a very wide spread overall in the number of IROs chosen. Around 30 appears to be average and it is noted by PwC that: “Clear tables laying out material topics, sub-topics and associated IROs are supremely helpful for readers.”

Location of the Sustainability Statement: Nearly ALL companies assessed include dthe sustainability statement either as part of the management report or outside the management report (but still inside the annual report). EY notes: “In the future, we can expect to find the sustainability statements in the management report (as required by the accounting directive)”

Level of Assurance: Most companies stuck to limited assurance however a small number of companies chose to do reasonable or a hybrid approach (e.g. where some of their data was under reasonable assurance and some was not)

Structure of the Statement: The vast majority follow ESRS 1 Appendix F structure. Example image provided by EFRAG below of this appendix.