全球商业气候联盟-CSRD气候报告内部-新会计时代的开始（英）-2025.6_93页_7mb

Summary of the CSRD Climate Reports Analysis

Introduction

This report analyzes the first year of CSRD (Corporate Sustainability Reporting Directive) climate-related reporting by the 100 largest listed EU companies, published in spring 2025. The goal is to highlight innovative and interesting reporting solutions rather than provide average or typical practices. The reports were manually reviewed, avoiding AI-based analysis, to ensure depth and quality of insights. The We Mean Business Coalition (WMBC) aims to support companies in reducing emissions by 50% by 2030, which is why climate-related reporting is a central focus of the analysis. The report also emphasizes the importance of high-quality, transparent reporting for investors and capital providers.

Methodology and Overall Statistics

• Sample Size: 100 largest listed EU companies as of December 31, 2024.

• Exclusions: 7 companies (6 Swedish, 1 French) were excluded due to non-compliance with CSRD requirements.

• Final Sample: 93 companies included in the analysis.

• Geographic Distribution:

  • Austria: 1
  • Belgium: 3
  • Denmark: 5
  • Finland: 2
  • France: 25
  • Germany: 21
  • Italy: 6
  • Netherlands: 14
  • Norway: 2
  • Spain: 11
  • Sweden: 3

• Sector Distribution (TRBC):

  • Basic Materials: 5
  • Consumer Cyclicals: 15
  • Consumer Non-Cyclicals: 6
  • Energy: 3
  • Financials: 22
  • Healthcare: 6
  • Industrials: 15
  • Real Estate: 1
  • Technology: 14
  • Utilities: 6

Assurance and Internal Controls

• Assurance Levels:

  • Reasonable assurance: 1 company
  • Limited assurance: 79 companies
  • Mixed assurance: 13 companies
  • No assurance: 0 companies

• Assurance Providers:

  • Deloitte: 16
  • KPMG: 14
  • PwC: 25
  • EY: 17
  • Forvis Mazars: 3
  • Others or joint assurance: 18

• Internal Controls:

  • Companies are required to disclose internal controls under GOV-5.
  • Many companies have not yet fully established their internal control systems.
  • Some companies, like Universal Music Group and BMW, have outlined plans for improving internal controls and aligning them with ERM (Enterprise Risk Management) frameworks.
  • AXA is a notable example for disclosing control monitoring outcomes and geographic compliance rates.

Qualifications and Restatements

• Restatement Trends:

  • 48 companies restated their comparison data.
  • 35 companies erased their historical comparison data.
  • 6 companies kept their comparison data unchanged.
  • 4 companies kept their data unchanged despite changes in accounting principles.

• Reasons for Restatements:

  • Companies restated data due to changes in methodology, acquisitions/divestitures, or errors in data or calculation.
  • Some companies, like KBC and Erste, have detailed policies on when and how to restate data, often based on a 5% threshold change in key performance indicators (KPIs).

• BBVA Example:

  • BBVA updated its sustainability reporting to align with ESRS (European Sustainability Reporting Standards) instead of the GRI framework.
  • They expanded the measurement boundary for Scope 3 emissions and added new decarbonization targets for additional sectors.

• Volkswagen Group Example:

  • VW adjusted their Scope 3 emissions data due to base-year recalculations.
  • They used production-volume-weighted life cycle assessments (LCAs) and included renewable energy certificates in their reporting.
  • Adjustments were made due to portfolio and regional shifts, and the use of a new data source for emission factors.

Key Observations

• Transparency: While some companies are transparent about their internal control shortcomings, others do not clearly disclose restatements, making it difficult for investors to assess data quality.
• Geographic Differences: French, Italian, and Spanish companies tend to report later than their Nordic and German counterparts, and their reports are often lengthy with limited hyperlinks.
• Assurance Practices: Most companies use traditional auditors for CSRD assurance, with joint assurance being common in France.
• Reporting Quality: The report highlights that restatements can indicate improved data quality and accountability, though they are not always clearly communicated.
• Future Focus: The report recommends reviewing the WMBC's internal control framework for guidance on setting up effective sustainability reporting systems.

Conclusion

This analysis serves as an inspiration for companies, auditors, and investors by showcasing diverse and thoughtful approaches to CSRD reporting. It emphasizes the importance of transparency, internal controls, and the evolution of sustainability reporting practices across the EU. The report encourages further exploration of the 100 CSRD reports and highlights the need for more standardized and user-friendly reporting to support sustainable investment decisions.