CSRD compliance statistics for 2026

CSRD compliance statistics for 2026 show a directive that is still being implemented unevenly. National laws remain incomplete, regulators have finished their first year of ESRS enforcement and assurance providers have reviewed hundreds of first-wave statements. This article brings together 25 findings from ESMA, national supervisors, assurance research, professional services firms and post-Omnibus surveys.

For companies, the practical issue is not only what must be disclosed. The same environmental data affects assurance effort, reporting cost, energy analysis and operational decisions. A reusable data structure can therefore reduce repeated collection work even when the legal perimeter changes.

The focus is compliance in practice. Who must report, what enforcers found, how assurance conclusions looked and what companies plan next. For the basics, start with our explainer on what the CSRD requires. For wider adoption figures, see our ESG reporting statistics for 2026.

CSRD compliance statistics at a glance

Finding	Figure	Source and period
Member States that missed the July 2024 transposition deadline	17 of 27	Freshfields CSRD implementation tracker, early September 2026
Member States still without compliant CSRD laws	5	Freshfields, early September 2026
Issuers’ sustainability statements in EEA enforcement scope	About 2,000	ESMA report on 2025 enforcement, May 2026
Content examinations that led to enforcement action	30%	ESMA, 2025 enforcement year
First-wave reports with only limited assurance	More than 94%	Sustainability Reporting Navigator brief, 600+ reports, October 2025
First-wave reports with a qualified assurance conclusion	1%	Sustainability Reporting Navigator, October 2025
Companies removed from scope that plan to keep or expand reporting	90%	osapiens survey, March 2026
ESRS routes provided for FY2026 statements from 10 November 2026	3	ESMA enforcement priorities, October 2026

4 CSRD transposition and legal status statistics

A company only has a legal CSRD obligation once its Member State has transposed the directive. The transposition map therefore still decides who must report in 2026, and under which national rules.

1. 17 of 27 Member States missed the July 2024 transposition deadline

The Freshfields tracker records that 17 of the 27 Member States failed to enact national CSRD laws by the July 2024 deadline. The European Commission opened infringement procedures against them in September 2024 by sending letters of formal notice, the first formal step in that process.

This historical finding explains why the first reporting year looked so different across countries. Some large companies reported under ESRS because national law required it, while comparable companies elsewhere stayed under the older NFRD rules. ESMA’s 2025 enforcement report confirms this split, noting that issuers in non-transposing countries remained subject to NFRD requirements even when they chose ESRS voluntarily.

The delay also affected more than the reporting standard. National laws decide practical questions such as who can provide assurance, how penalties work and where the statement must be published. A company with subsidiaries in several Member States could face different answers to each question in the same year.

Multi-country groups should therefore map obligations entity by entity rather than assume a single EU rulebook. Our guide to national CSRD transposition shows why the national text matters for penalties and audit rules.

2. 5 Member States still lacked compliant CSRD laws in September 2026

As of early September 2026, 5 Member States had still not enacted compliant CSRD laws, according to Freshfields. That was despite a December 2025 deadline to transpose the “Stop-the-clock” directive, which postponed the later reporting waves.

More than two years after the original deadline, the directive is not fully in force across the EU. Freshfields notes that, in the meantime, reporting is only required from large listed companies and regulated financial institutions in Member States that have transposed the CSRD. Companies in the remaining countries report under NFRD-based rules, although they can apply ESRS voluntarily.

Luxembourg shows how long the process can take. The CSSF’s August 2025 review noted that the national transposition bill was still under review after amendments to align it with the Stop-the-clock directive. Even so, many Luxembourg issuers chose to report under ESRS anyway, as the assurance section below shows.

Freshfields expects CSRD laws to be in effect across the whole EU by the time companies report on financial years starting in 2027. Until then, reporting processes built around one country’s rules may need changes once the remaining laws pass. A flexible data structure is safer than a country-specific workaround.

3. Member States have 12 months to transpose Omnibus I

Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026 and took effect on 18 March 2026. Member States must transpose the relevant amendments by 19 March 2027.

This starts a second implementation cycle while some countries are still finishing the first. Under the amended directive, the obligations extend to large private EU companies from financial years starting in 2027, and to non-EU groups with a large EU presence from 2028. Our summary of the approved Omnibus changes covers the new thresholds in detail.

The two cycles overlap in practice. A country can transpose the original CSRD and the Omnibus amendments in one law, or update a law it passed only recently. Either way, companies need to read the final national text rather than rely on the EU directive alone.

For companies newly in scope, the timing is tight. The CSRD reporting timeline after Omnibus I shows how little preparation time remains once national laws are final, especially for groups that need a full year of data before the first reporting year closes.

4. Denmark’s issuers in enforcement scope fell from 133 to 43

ESMA’s country annex shows Denmark with 133 issuers in sustainability enforcement scope in 2024 and 43 in 2025. The drop reflects February 2026 executive orders that exempt Wave 1 issuers, which Omnibus I will remove from scope, from reporting on financial year 2025.

About two-thirds of the Danish enforcement population left within a single cycle. It is the clearest national example of how quickly scope can change once a Member State acts on the Omnibus.

The Danish change also explains most of the EU-wide decline. The total population in enforcement scope fell by 108 issuers between 2024 and 2025, from 2,092 to 1,984. Denmark alone accounts for 90 of that reduction, so the wider population was largely stable.

The legal obligation ends for these companies, but data requests from banks, customers and investors usually continue. That is why leaving CSRD scope does not remove sustainability risk. Keeping the data model in place makes it easier to answer those requests and to return to full reporting if thresholds or circumstances change.

How Dcycle supports CSRD compliance in practice

The statistics in this article point to one operational problem. Rules differ by country, enforcers focus on climate and general disclosures, and assurance providers flag data gaps. The scenario below shows how a reporting team can turn that into a repeatable process.

A listed group preparing its second ESRS statement

Consider a listed industrial group with 1,800 employees, €620 million in turnover and 14 sites across Spain, Portugal and Germany. Its first ESRS statement, for financial year 2024, received limited assurance with Other Matter paragraphs on Scope 3 estimates.

The group now faces three pressures. If its enforcer selects the statement for review, ESRS E1 climate disclosures are the most likely focus. Its German subsidiary follows a different legal timeline. Its CFO wants the same energy data to support a cost reduction plan.

One structure for entities, evidence and approvals

With multi-entity management, the group sets up one hierarchy of subsidiaries and sites. Each site gets owners, tasks and files, data rolls up automatically, and country-specific emission factors apply by location. The reporting boundary is visible before any number reaches the report.

Automated data collection connects to ERPs and accounting tools and reads uploaded invoices, PDFs and spreadsheets. Evidence and traceability then records who uploaded each file, when values changed and which calculation chain and emission factors produced each result. When the assurance provider asks how a Scope 3 estimate was built, the team shows the method instead of rebuilding it from emails.

Roles and approval workflows define who uploads, reviews and approves data at each entity, with every approval logged.

Linking reporting with cost and operational decisions

For electricity, gas and water invoices, the platform also extracts the total amount and currency. Sustainability and finance can compare emissions and energy spend by site, find the plants with the highest energy intensity and prioritise efficiency projects there.

When next year’s statement is due, multi-framework reporting keeps last year’s structure and refreshes the figures with new data. The same data points feed other frameworks such as the GHG Protocol, CDP or EcoVadis.

This does not replace the judgement of the reporting team, auditors or legal advisers. It reduces manual collection and reconciliation, so experts can spend their time on materiality, targets and narrative.

5 CSRD enforcement statistics from European regulators

ESMA’s report on 2025 enforcement is the first EU-wide view of how national enforcers supervised ESRS statements. It covers examinations carried out in 2025, mainly of financial year 2024 statements, across the European Economic Area.

1. About 2,000 issuers’ sustainability statements were in enforcement scope

At the end of 2025, approximately 2,000 issuers’ sustainability statements were within enforcement scope across the EEA. ESMA’s annex gives an exact total of 1,984, down from 2,092 in 2024.

The population is concentrated in a few markets. Sweden had the largest number of issuers in scope (299), followed by Germany (268), France (223) and Italy (142). The count includes statements still prepared under NFRD-based rules in countries that had not transposed the CSRD, as well as EEA countries outside the EU such as Norway.

These are listed issuers supervised by national enforcers under EU transparency rules. Large non-listed companies are outside this population, so the figure is not a count of all CSRD reporters. Once large private companies enter scope from financial year 2027, the total number of reporters will be much larger than the enforcement population.

For listed companies, the figure confirms that their statement belongs to a defined population that enforcers actively sample. A sustainability statement now sits alongside the financial statements as a regulated part of the annual report, with the same expectation of supervision.

2. Enforcers carried out 402 examinations at an 18% rate

National enforcers undertook 402 examinations of sustainability statements in 2025, compared with 573 in 2024. They examined 367 issuers, down from 425 the year before. The examination rate was 18%, counting content examinations only.

Of the 402 examinations, 263 related to statements prepared under the CSRD and ESRS and 139 to statements under NFRD rules. Under the NFRD, a small share of reviews (9%) only checked whether a statement existed, while the rest assessed its content.

ESMA describes 2024 as unusually high and 2025 as in line with earlier years. It also notes that first-time ESRS examinations take longer than NFRD reviews because the framework is far more detailed. As enforcers gain experience, the number of ESRS examinations they can complete each year may rise.

An 18% annual rate means that, over several years, a review is something listed issuers should plan for rather than treat as a remote possibility. Teams that keep evidence organised during the year can respond to an enforcer’s questions without disrupting the next reporting cycle.

3. 25% of ESRS examinations covered voluntary statements

Of the 263 examinations of statements prepared under the CSRD and ESRS, 25% concerned statements prepared voluntarily in Member States that had not yet transposed the directive.

ESMA reads this as a sign that issuers began their ESRS journey even before they were legally obliged to. Enforcers in those countries also started shifting their supervisory focus towards ESRS reporting. ESMA’s separate sample of 101 issuers points in the same direction, with 37% reporting under ESRS voluntarily and 63% following national transposition.

Voluntary ESRS reporting therefore did not escape scrutiny. ESMA adds a caveat, though. Supervision of mandatory and voluntary statements may not be fully equivalent, because the legal bases differ, particularly when it comes to enforcement actions.

Companies that adopt the ESRS framework voluntarily should expect to be judged against it. Claiming ESRS alignment raises the standard of evidence that readers and supervisors will expect.

4. 30% of content examinations led to enforcement action

The 367 content examinations of CSRD and NFRD statements led to enforcement actions towards 109 issuers. That is an action rate of 30%, compared with 28% the year before, when there were 125 actions.

Under ESMA’s guidelines, enforcers can require a reissued statement, a public corrective note or a correction in a future statement. Most actions in 2025 were corrections in a future statement. Enforcers also issued other recommendations that did not count as formal actions because they did not relate to a material infringement.

ESMA describes this as a measured approach that acknowledges the learning curve issuers are on and the changing rules during the Omnibus period. Even so, enforcers acted on almost one in three examined statements, which shows that first-year leniency did not mean an absence of findings.

A correction required today becomes a checkpoint in next year’s review. Issuers that receive one should document how they fixed the issue, because the enforcer is likely to check it in the next statement.

5. Climate and general disclosures drew 40% and 36% of actions

Most actions on CSRD and ESRS statements related to climate change under ESRS E1 (40%) and general disclosures under ESRS 2 (36%). One action can cover several areas of non-compliance, so the shares should not be added together.

ESMA suggests climate attracts more actions because it is a more mature reporting area, which gives enforcers higher expectations. ESRS 2 covers the basis of preparation, governance, strategy and the materiality process, so weaknesses there tend to affect the rest of the statement.

The picture was different for statements still prepared under NFRD rules. There, 84% of actions related to EU Taxonomy reporting, which ESMA links to the more precise requirements of the Taxonomy regime compared with the broader NFRD wording.

For reporting teams, E1 and ESRS 2 deserve the most review time. That means traceable emissions inputs, clearly described targets and transition plans, and a general disclosures section that accurately describes the process the company actually followed.

5 disclosure quality statistics from the first ESRS statements

Regulators and analysts have also reviewed what the first statements contained, beyond formal enforcement actions. ESMA’s samples ranged from 91 to 117 issuers in 27 EEA countries and were selected on risk rather than at random, so ESMA warns that the findings should not be extrapolated to all issuers.

1. 60% of reviewed issuers gave satisfactory materiality process disclosures

ESMA’s fact-finding exercise on 91 listed issuers’ first ESRS statements found that 60% disclosed satisfactory information on their double materiality assessment process. These issuers gave adequate detail on thresholds, input parameters or stakeholder engagement.

Enforcers still found many descriptions boilerplate, with little detail on how issuers had adapted the required or suggested steps to their own situation. Almost 90% described their impacts, risks and opportunities, but different terminology sometimes made them hard to map to ESRS topics and to the related topical disclosures.

The materiality findings led to enforcement actions for 8 issuers, mainly over missing topical disclosures, unclear descriptions of stakeholder consultation and incomplete lists of disclosures. In Luxembourg, the CSSF found a similar pattern, with 84% of issuers explaining how they used thresholds but some struggling to describe the judgements behind them.

Materiality drives every later disclosure, so the process description is worth strengthening first. Our double materiality guide covers thresholds, stakeholder input and documentation.

2. Only 70% gave complete information on datapoints from other EU laws

In the same review, 90% of issuers listed the ESRS disclosure requirements they complied with. 85% listed the datapoints derived from other EU legislation, but only 70% reported complete information on them.

These datapoints, listed in an appendix to ESRS 2, connect the sustainability statement with rules such as the SFDR, Pillar 3 bank disclosures and the EU climate benchmarks. Banks and investors rely on them to meet their own reporting duties, so gaps flow through to their disclosures too.

Enforcers also noted that some issuers placed these lists in an appendix outside the designated section, which made them harder to find. The issue is presentation as much as content.

The overlap with Taxonomy reporting adds a further layer. Our comparison of the EU Taxonomy, CSRD and ESRS explains how these regimes overlap and where the same data can serve more than one requirement.

3. 90% aligned sustainability and financial reporting scopes

ESMA’s sample of 101 issuers showed that 90% prepared the sustainability statement for the same scope as their financial statements. 86% followed the four-part structure prescribed in ESRS 1, and 71% also applied the more detailed, non-binding structure suggested in the standard.

The other 10% cited recent acquisitions, partial reporting for some topics or entities, or other scope limits. Enforcers also found inconsistencies at some issuers that had confirmed alignment.

Connectivity was a weaker area. Only 35% of the sample provided full information linking the sustainability statement to other parts of the corporate report. 21% provided partial links, 29% made no such disclosure and for 16% enforcers found no real connection, because financial figures in the statement were not linked back to the financial statements.

Incorporation by reference raised similar issues. 73% of issuers used it to point readers to other parts of the annual report, and 14% of those did not meet the ESRS conditions, for example by giving vague references without page numbers or working links. Boundary alignment and clear references are among the simplest things an enforcer can check, and among the easiest to fix early.

4. Only 26% disclosed anticipated financial effects

The CSSF’s review of first-year reports, published in August 2025, examined Luxembourg issuers’ 2024 reports. Only 26% disclosed the anticipated financial effects of material risks and opportunities, and 58% disclosed time horizons for their material impacts, risks and opportunities.

The wider picture was mixed. Almost 40% of issuers gave at least some information on financial effects, often qualitatively or in ranges. Issuers reported 39 material impacts, risks and opportunities on average, with a range from 11 to 100, and located 75% of them in their own operations on average.

The CSSF links part of the gap to phase-in provisions that give issuers more time to develop methods. The sample is small and ESRS reporting was voluntary in Luxembourg in 2024, so the figures should not be generalised to the EU.

They still point to the next maturity step, which is connecting sustainability risks with financial planning through shared data. ESMA makes the same point in its 2026 priorities, noting that some issuers omit the current financial effects of their material impacts, risks and opportunities.

5. Almost 70% disclosed GHG emission reduction targets

Inits study of 250 first CSRD statements, published in April 2025, PwC found that almost 70% of companies disclosed greenhouse gas reduction targets. In energy, utilities and resources, and in industrial and services, only around half did.

The same study found that the least common reporting topics were biodiversity and ecosystems (46%), pollution (42%), water and marine resources (36%) and affected communities (31%). Companies disclosed 47% more negative impacts than positive ones in aggregate, and 80% mentioned sustainability risks in the risk factors section of their annual report. More than 70% of the sample came from five countries, three of which had not yet transposed the CSRD.

A smaller KPMG review of 50 early ESRS statements, published in January and February 2025, found that 74% of companies had a net zero target and 84% of those referenced the Science Based Targets initiative. Fewer than one-third reported on actual emission reductions, which shows the gap between setting a target and evidencing progress.

Targets are part of ESMA’s FY2026 focus, so companies without a clear emissions target or method should close that gap first. Our article on emissions intensity metrics for CSRD and SBTi explains how intensity and absolute targets fit together.

4 CSRD assurance statistics

Limited assurance is mandatory for CSRD statements, and the first wave shows how assurance providers responded in practice.

1. More than 94% of first-wave reports received only limited assurance

The Sustainability Reporting Navigator compared more than 600 first-wave CSRD reports. More than 94% received only limited assurance, and nearly 90% of engagements were carried out by the Big Four.

PwC’s sample of 250 statements found only one company with reasonable assurance over its full statement. Others obtained reasonable assurance for a subset of information, usually greenhouse gas emissions or own workforce data.

National practice also shaped the reports. The Navigator brief singles out France, where assurance reports follow a prescribed three-part format under the national audit oversight body, as the most structured and transparent approach.

Limited assurance is lighter than a financial audit, but it still involves evidence requests, process walkthroughs and sample testing. Our guide to preparing for a sustainability audit explains what auditors typically ask for.

2. 1% of reports included a qualified conclusion

According to the same brief, 1% of reports included a qualified conclusion. The qualifications related mainly to incomplete Scope 3 data, omitted sites or omitted disclosures.

A low qualification rate reflects the limited assurance level, first-year reliefs and the novelty of the standards. It does not mean the reports were flawless. The Navigator authors found that data completeness remained uneven, that Scope 3 figures were hard to compare across companies and over time, and that ambiguity in parts of the ESRS reduced clarity.

The causes of qualification are instructive. Incomplete Scope 3 emissions and missing sites are coverage problems, which are much easier to prevent through a complete entity list and supplier data plan than to explain after the fact.

As limited assurance becomes routine, providers are also likely to expect improvement year on year. A gap accepted in a first report is harder to justify in a third.

3. 99% of assurance reports carried Inherent Limitation paragraphs

Assurance providers used Inherent Limitation paragraphs in 99% of reports, Other Matter paragraphs in 70% and Emphasis of Matter paragraphs in 12%.

These paragraphs highlight measurement uncertainty, estimates and limits on comparability. PwC observed the same pattern, with practitioners drawing attention to uncertainty in quantitative metrics, difficulties comparing information across companies and time, and the double materiality process.

They do not change the conclusion, but investors and enforcers read them. The Navigator authors recommend clearer and more informative assurance reports, including key audit matters and more context on data quality, assumptions and uncertainty ranges.

Companies can influence how these paragraphs read. Documenting assumptions, sources and ranges for the largest emission categories helps assurance providers describe uncertainty precisely and supports clearer reports over time.

4. 63% of voluntary Luxembourg reports received limited assurance

The CSSF found that 63% of the Luxembourg reports it reviewed received limited assurance for 2024, while the rest were unaudited. One more report had limited assurance over selected information only.

Luxembourg had not transposed the CSRD, yet almost 60% of the issuers with published reports had voluntarily applied full ESRS requirements. Of the 33 issuers covered, 17 reported under full ESRS, 6 followed some ESRS requirements, 6 reported under NFRD rules and 4 had not yet published, mainly because of a later year end.

The CSSF also found that reports grew 44% longer on average, but were better structured than the 2023 versions, which made information easier to find.

Many companies treat assurance as part of credibility rather than a legal formality. Seeking assurance voluntarily also prepares the reporting team for the evidence standards that will apply once national law makes it mandatory.

4 compliance intention statistics after Omnibus I

Omnibus I has removed many companies from mandatory scope. The following survey findings describe intentions rather than observed behaviour, so they are best read as signals.

1. 90% of companies removed from scope plan to maintain or expand reporting

An osapiens survey reported by ESG Today in March 2026 covered more than 400 executives at European companies with over 1,000 employees. Among companies taken out of scope, 90% intend to maintain or expand their reporting, and 86% say they can keep producing reports aligned with CSRD-level standards.

The reasons are practical. Respondents already use sustainability data in operational and resource planning (53%), innovation and process design (48%), financial planning and investment decisions (38%) and supply chain risk assessment (38%).

The survey comes from a software vendor, which should be noted when citing it. Even so, the direction matches the KPMG finding below and the voluntary reporting rates seen by ESMA and the CSSF.

For companies now outside scope, the VSME standard offers a lighter structure for answering customer and bank requests without the full ESRS workload.

2. 84% expect fewer internal resources over time

The same survey found that 84% expect reduced regulatory scrutiny to eventually mean fewer internal resources for sustainability reporting. In the near term, 90% expected investment in reporting solutions and automation to increase over the next 12 months.

Respondents also described the benefits they want to protect. They cited better visibility into climate, supply chain and operational risks (49%), stronger investor confidence and readiness for ESG data requests (44%), meeting customer or partner audit requirements (44%) and better integration of financial and sustainability decisions (43%).

90% said sustainability reporting is already partly or fully integrated with financial reporting at their company.

Together, the figures suggest teams expect to do similar work with fewer people. That makes efficient data collection, clear ownership and the reuse of the same data across outputs more important than before.

3. 43% cite the cost of data collection and analysis as a barrier

Respondents named budget constraints around data collection and analysis (43%) as a top barrier. Fragmented data across tools and systems (40%), poor system integration (31%) and unclear ownership or accountability (29%) followed.

These barriers are operational, not regulatory. They also connect with ESMA’s findings on weak links between sustainability and financial reporting, which are harder to fix when data sits in separate systems with no clear owner.

Our ESG reporting challenges statistics show a similar pattern in other surveys, with data quality, value chain complexity and staff capacity near the top.

Cost and fragmentation tend to reinforce each other. Every additional spreadsheet or manual hand-off adds collection time, review effort and the risk of inconsistent figures across reports.

4. 75% of continuing reporters planned to use ESRS before it was required

KPMG surveyed 128 companies from 17 countries in March 2025, 62 of them German. In its first-wave CSRD report, three in four of the 84 companies planning to keep reporting said they would use ESRS before it was required. Two-thirds of the 23 companies outside the proposed Omnibus scope planned to report voluntarily.

At the time, 92 of the 128 respondents (72%) expected to remain in scope because they had more than 1,000 employees. The survey therefore leaned towards larger companies, many of them in Germany, where the CSRD had not been transposed.

This historical finding predates the final Omnibus thresholds, and the out-of-scope base is small. Use it as context for the later osapiens survey rather than as a current measure.

Its main value is consistency. Two surveys a year apart, with different samples and methods, both found that most companies intend to keep reporting once the legal requirement is removed.

3 areas enforcers will check in FY2026 statements

ESMA published its 2026 enforcement priorities in October 2026. They apply to FY2026 annual reports published in 2027 and show where enforcers will look first.

1. Issuers can choose between 3 ESRS versions for FY2026

Commission Delegated Regulation (EU) 2026/1563 is scheduled to enter into force on 10 November 2026. For financial years starting in 2026, it provides three routes: ESRS Set 1 with the quick fix, the simplified Set 2, or Set 1 with a closed list of Set 2 reliefs. ESMA describes FY2026 as a transitional year for this reason.

ESMA expects issuers to state which version they used, for example in the basis for preparation. Issuers that combine Set 1 with Set 2 reliefs cannot extend the list of reliefs beyond those in the regulation.

Comparability is the other concern. Where the choice of version affects year-on-year comparisons, ESMA expects issuers to say so and to indicate the affected disclosures. Restated comparative figures should also be clearly flagged.

Our guide to choosing an ESRS version for FY2026 covers the trade-offs for comparability and effort.

2. ESMA set 2 sustainability enforcement priorities

ESMA’s 2026 priorities for sustainability statements are continued progress on materiality assessment and connected reporting. Connected reporting links impacts, risks and opportunities with policies, actions, targets and metrics.

On materiality, ESMA asks issuers to assess positive and negative impacts with the same rigour, because some statements describe positive impacts in far more detail. It also wants concise, company-specific process descriptions and asks issuers to use entity-specific topics only when the ESRS categories genuinely do not fit.

On connectivity, issuers must say when a material impact, risk or opportunity has no related policy, action or target. They should also make clear when a target covers only part of the issue, for example own operations but not the value chain.

Both priorities build directly on the 2025 findings, where materiality disclosures were often boilerplate and links between sections were often missing.

3. 2 topical standards will receive closer scrutiny

Enforcers will focus on ESRS E1 Climate change and ESRS S1 Own workforce in FY2026, citing the maturity of these topics. Taxonomy disclosures also remain under supervision, although ESMA has not set specific Taxonomy priorities while the delegated acts are being revised.

For E1, ESMA highlights several practical points. Issuers should state explicitly whether targets are science-based and compatible with 1.5°C, disclose absolute values and not only intensity values, separate gross reduction targets from net targets, and explain any change in baseline, target or method.

For S1, ESMA wants a clear distinction between broad commitments and actual targets that are measurable, time-bound and outcome-oriented.

With E1 linked to 40% of 2025 actions, climate is where weak evidence is most likely to be noticed. Workforce data, often held in HR systems outside the sustainability team, is the next area to strengthen.

How to cite and compare these CSRD compliance statistics

The figures come from different populations and periods.

ESMA enforcement data covers listed issuers and examinations carried out in 2025, mostly of FY2024 statements.

Disclosure quality data comes from defined samples, with 91 to 117 risk-selected issuers for ESMA, a small Luxembourg population for the CSSF and 250 statements for PwC.

Assurance data from the Sustainability Reporting Navigator covers more than 600 first-wave reports.

Survey data from osapiens and KPMG reflects intentions. The osapiens survey comes from a software provider, and the KPMG survey predates the final Omnibus agreement.

Transposition data reflects the Freshfields tracker in early September 2026 and can change quickly.

Do not combine percentages from different studies into one average. Cite each figure with its source, sample and period.

CSRD compliance in 2026 is moving from first filings to repeatable evidence

The first full CSRD cycle has produced a clearer picture. Transposition is still incomplete and Omnibus I has started a second implementation cycle. Enforcers acted on 30% of examined statements, with climate and general disclosures at the centre. Assurance providers rarely qualified conclusions, but nearly all added paragraphs on limitations.

The next phase rewards consistency. Companies still in scope need statements that hold up to repeated review, with traceable data, aligned boundaries and clear links between materiality, targets and metrics. Companies outside scope still face data requests and mostly plan to keep reporting with fewer resources.

In both cases, the advantage goes to teams that collect data once, document it well and reuse it across reporting and business decisions. That approach also makes changes in scope easier to absorb because the company does not need to rebuild its evidence base for each request.

The strongest compliance process is therefore a durable environmental data process. It connects source records, calculation methods, organisational boundaries and approvals, then makes the resulting information available for assurance, financial planning and operational improvement.

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