The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) published the results of a review of first-year CSRD-style sustainability reporting by supervised issuers, based on 2024 sustainability reports prepared fully or partially under the European Sustainability Reporting Standards (ESRS). The review finds broad voluntary uptake and more structured, accessible sustainability statements than in 2023, but identifies uneven quality in double materiality assessments and gaps in the disclosure of material impacts, risks and opportunities (IROs). The CSSF analysed a sample of 19 reports and notes that almost 60% of issuers reviewed reported on a voluntary basis using full ESRS requirements, with 63% of those receiving limited assurance. While all issuers describe their double materiality assessment (DMA) process and include stakeholder consultation, practices vary widely, with 84% providing some explanation of thresholds used to determine material IROs. Around half use materiality matrices to present DMA results, and the CSSF encourages clearer visualisations that show threshold levels and stakeholder importance, ideally including non-material topics for transparency. Key challenges highlighted include the treatment of entity-specific topics (47% disclose at least one topic beyond the ESRS list, with the CSSF questioning whether some are truly distinct and material), weak linkage between material topics and IROs, limited disclosure of financial effects (almost 40% provide some information, with anticipated effects disclosed by 26%), incomplete time-horizon disclosure (58%), and a widespread lack of clarity on whether impacts are assessed and disclosed on a gross or net basis. Looking ahead, the CSSF points to ongoing EU-level discussions on the Omnibus Directive, which includes proposals to limit the scope of the CSRD and amend the ESRS, alongside a revised ESRS being prepared by EFRAG. It will continue to monitor CSRD-aligned sustainability reports and indicates that supervisory actions will be proportionate.
Luxembourg Commission de Surveillance du Secteur Financier 2025-08-18
Luxembourg Commission de Surveillance du Secteur Financier review finds nearly 60% of issuers voluntarily applied full ESRS and flags double materiality disclosure gaps
The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) reviewed first-year CSRD-style sustainability reporting, noting broad voluntary uptake and improved accessibility but uneven quality in double materiality assessments and disclosure gaps. Analysis of 19 reports showed 60% of issuers used full European Sustainability Reporting Standards (ESRS), with 63% receiving limited assurance. The CSSF highlights challenges in linking material topics to impacts, risks, and opportunities, and notes ongoing EU discussions on potential amendments to the CSRD and ESRS.