"Wave one" companies have produced their first sustainability reports under the CSRD – gaining valuable experience, but not always with the desired results. What lessons can be learned for future reporting cycles? Which requirements are often underestimated, what do auditors particularly value, and how can processes be specifically improved before the audit becomes a stress test? Whether you are already required to report or are still in preparation, these insights will help you avoid typical mistakes and make your reporting robust and audit-proof right from the start.
The Corporate Sustainability Reporting Directive (CSRD) has been in force since 1 January 2024. All capital market-oriented companies with more than 500 employees must prepare a CSRD-compliant sustainability report for the first time for the 2024 financial year – publication will take place in 2025. From then on, the obligation for external auditing will also apply – initially with limited assurance by auditors.
If the audit is not passed
A negative audit opinion has consequences: loss of reputation, resulting jeopardy to important business relationships, possible fines from regulatory authorities, and additional financial and time expenditure. One of the potential pitfalls on the path to a CSRD-compliant sustainability report is an incorrectly performed double materiality analysis (DMA). It forms the core of CSRD reporting and is the basis for the entire sustainability report.
Typical weaknesses and areas for improvement
Incomplete DMA: A lack of stakeholder involvement or inadequate documentation often leads to auditors refusing to provide the necessary assurance. Companies should apply clearly defined methods specified in the ESRS, document results transparently and seek dialogue with auditors at an early stage.
Lack of management support: Without the active support of the board and top management, necessary resources often remain severely limited. A clear ‘tone from the top’ is therefore crucial – not least due to the personal liability risks for board and supervisory board members.
Data quality and internal controls: Many reports fail due to inconsistent ESG data, inadequate IT infrastructure and a lack of verifiability. Audit-proof documentation, clear processes and ESG controlling – in line with financial reporting – help ensure reliability.
Uncertainties with new ESRS standards: Misinterpretations can quickly lead to incorrect information. Targeted consulting, CSRD trainings and close coordination with the auditor provide certainty in this area.
Quick Fix: relief for 2025/26
With the quick fixes from July 2025, the European Commission has introduced amendments regarding the transition to CSRD reporting.
Scope 3 emissions: postponement of initial reporting to 2026 for companies with ≤750 employees
Biodiversity (ESRS E4): postponement of full reporting until the second reporting period (2026)
Detailed information on social and governance issues (ESRS S1-S4): simplified disclosures and postponements for 2025
Important: These simplifications provide extra time, but do not exempt from the requirement to clearly indicate material topics that have not yet been fully reported.
Recommendations for first wave companies
Benefit from CSRD consulting: External expertise helps to avoid mistakes and implement best practices.
Optimise the double materiality analysis: Involve stakeholders at an early stage, apply a clear methodology and document the results in a comprehensible manner.
Actively seek out dialogue with auditors: A pre-assurance check or internal audit before 2026 can reveal critical shortcomings before they become costly.
Take advantage of the quick-fix leeway – and simultaneously build up data: Those who start early with the structured recording of Scope 3, biodiversity and social indicators will be well prepared for the 2027 audit.
Conclusion: How to make the next audit a success
Companies that failed their first CSRD audit can use the following year as an opportunity: through an optimised double materiality analysis, improved data quality and clear governance-structures, they can ensure that the 2026 sustainability report not only passes the audit, but also strengthens trust among investors, customers and employees.
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Since 2018, I have been working at EurA as a sustainability consultant and have been leading the services division, currently comprising 12 team members, since 2020. In parallel, I manage our greenhouse gas verification body, accredited since 2024, and support the development of sustainable investment projects as a GHG assessor (EU Innovation Fund) and expert for Green Assist (EU LIFE). After studying chemistry at the University of Jena, I completed a PhD as part of a DBU scholarship, focusing on integrating sustainability criteria into research, development, and education. As a postdoctoral researcher, my work centered on the environmental assessment of chemical and pharmaceutical processes. Driving sustainability throughout the full lifecycle of products, processes, and innovations – from the initial idea to market entry – gives me a deep sense of purpose. I truly value the inspiring exchange with clients and partners. In my free time, I enjoy being in nature, reading, or discovering new culinary specialities.
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