CSRD Reporting 2025 – Communication, readability and best practice from Nordic large-cap companies

A 38-page sustainability report. Another at 130 pages. Both prepared under the same regulatory framework, the same standards, the same requirements for transparency and comparability – and yet barely comparable. The starting point of this year’s review of sustainability reports prepared in accordance with CSRD has shifted from structure to content. Companies have moved past the implementation itself, but our review shows that they now face other, greater challenges. 

AVA has reviewed 25 sustainability reports from Nordic large-cap companies, with the aim of understanding how companies communicate their sustainability work in a new regulatory landscape. The analysis spans sustainability reports across different industries including FMCG retail, telecoms, finance and energy. 

Last year’s analysis showed that structure was the central challenge in companies’ sustainability reporting. The analysis focused on who was following the ESRS standards. who was building their own logic and who was managing to navigate a regulatory framework that few had yet fully mastered. This year the question is different. The structure is in place at most companies. The focus has shifted to how well the companies  communicate – and whether the information actually creates understanding, rather than merely fulfilling requirements and ticking boxes. It is also worth noting that, thanks to the companies that reported under CSRD already in 2024, those reporting for the first time in 2025 have had something concrete to draw from , both for inspiration and guidance. 

Four observations from this year’s reports

Below are four overarching observations from the analysis, followed by a more detailed review with examples from the CSRD reports analysed. 

1. IROs need a name
Several companies list their impacts, risks and opportunities (IROs) without naming them, or use ESRS sub-topics as labels without identifying specific impacts, risks or opportunities within them. This approach makes it difficult to track how an identified impact, risk or opportunity is followed up throughout the report. The clearest reports name their IROs and refer back to them consistently. 

2. Communicate phase-in early and clearly
Almost all reporting companies apply the phase-in¹ rules, but how this is communicated varies considerably. Some companies choose to collectively disclose which disclosure requirements are being phased in already under general disclosures, preferably in a clear table or bullet list. Other companies mention it only in an appendix or in the ESRS index, which risks creating confusion for the reader about what the report actually covers. 

3. Prioritise readability
Many reports are text-heavy and lack visual elements to help the reader navigate. This applies not only to design and layout – how the content is communicated matters just as much. A report that is well-structured but written like a legal document, filled with vague formulations without time horizons or concrete actions, will not reach the reader regardless of how good the design is. 

4. Choose tables over narrative text 
A clear shift in this year’s reports is that more companies are presenting policies and stakeholder dialogues in table format rather than in narrative text. For the double materiality assessment, however, development is moving in the other direction, with an increasing number of companies choosing to remove the matrix in favour of narrative text. 

Below is a more detailed review of each of these areas, with examples from this year’s reports. 

IROs need a name

How IROs are presented and specified is one of the areas where the spread between reports remains large. A recurring problem is that companies use sub-topics as labels, or do not name their IROs at all. Some companies also group their impacts, risks and opportunities under a sub-topic without clearly breaking them down into specific impacts, risks or opportunities, making it difficult to track the connection to policies, actions and targets. It also occurs that IRO tables are only presented at one level, either under general disclosures or at a topic level, making a complete overview difficult. Conversely, there are companies that present equally detailed information at both levels; the question there is rather how the two levels can complement rather than duplicate each other. 

The clearest reports present IROs consistently at two levels with clear names for each IRO: this is done through an overarching summary under general disclosures and then a more detailed description per topic, or the reverse, with a more detailed description under general disclosures and a shorter reference per topic. Both methods work well, as long as IRO:s are named and recur consistently throughout the report. A shift in that direction is visible in this year’s reports. Equinor now explains IROs more thoroughly in tables under each topic rather than in narrative text, making them easier to absorb. SEB complements a detailed IRO table under general disclosures with a shorter summary table per topic. The two levels complement rather than duplicate each other, making it easy for the reader to get both an overall picture and quickly orientate themselves within a specific topic. Both Equinor and SEB have named their IROs, which makes the cross-referencing clearer. 

Well-presented IROs are a good foundation, but how they then connect to the policies, actions and targets described later in the report is crucial. The connection is often made at topic level rather than IRO level, making it difficult to track how a specific impact, risk or opportunity is actually addressed. The result is that the reader either knows what the IRO is called but not how it is managed, or understands how a topic is handled but cannot trace it back to a specific IRO. 

There are companies that have succeeded in linking IROs to policies, actions and targets. Netcompany is one example that, despite not naming its IROs, connects material sub-topics to policies in a policy overview under general disclosures. Vestas goes even further and has a policy overview under general disclosures that connects to its material topics and describes which topic areas and types of IROs are addressed. Under each topic chapter, each IRO is also described in detail with how the company intends to reduce the impact, manage the risk or capitalise on the opportunity. Several IROs are also directly linked to targets, making it easier to understand the connection to actions. Ørsted presents IROs, policies, actions and targets on a summary page for each topic under general disclosures, and then describes each IRO in more detail per topic, with information about the type of impact, risk or opportunity and where in the value chain it arises. The narrative text gives the reader an understanding of the connection to the business model, making it easy to follow the logic through to the concrete actions. 

The traceability of IROs is an area where there is clear room for improvement in the next reporting cycle, not least for companies that already have good structure in place but do not quite maintain the clearthread throughout the sustainability report. 

Communicate phase-in early and clearly

Almost all companies in this year’s analysis apply the phase-in rules, but how this is communicated varies. Some mention which requirements arebeing phased in only in an appendix or in the ESRS index without further explanation elsewhere in the report, which risks creating confusion about what the report actually covers. Others mention in the general disclosures that the phase-in provisions have been applied, without specifying which disclosure requirements are affected. Although all companies have included the information in an appendix, it often becomes insufficient from a reporting perspective. 

The clearest reports disclose the phase-in provisions collectively already under general disclosures, preferably in table format, so that the reader immediately understands what is covered and what has been omitted. That said, where exactly in the report this appears varies. ICA Gruppen has a clear table included under BP-2 in the general disclosures that encompasses all disclosure requirements for which they have applied phase-in provisions. SBAB discloses the phase-in provisions under BP-2 in the general disclosures in narrative text, while Axfood opts for bullet list format in the same place. Equinor stands out with a full-page table at the end of the sustainability report that collects all phase-in provisions with descriptions, and refers to it from IRO-2 under general disclosures. The approach makes it easy for the reader to get a complete picture.

Which method works best depends on the extent of the phase-in. A company phasing in a small number of disclosure requirements can manage it with a short piece of running text, while a company phasing in the majority of requirements does the reader a service with a consolidated table.

Prioritise readability

Readability is an area where the differences between reports are clear. Many reports are extensive with small font sizes, small headings and few visual elements, making it difficult to absorb the information even though the content itself may be well-structured and thorough. The lack of clear ESRS codes further hampers navigation. Companies using portrait format also face a particular challenge, as the format provides less space for an airy layout and visual breaks. 

The companies that stand out are those that have actively worked to make their report more accessible. Vattenfall, for example, improves readability by presenting an additional table of contents under each topic, making it easy to navigate even in a long report. SEB has consistently used the ESRS code together with the topic name as a heading, making the report both more searchable and easier to navigate. 

A well-designed report is, however, only half the work. How the content is actually communicated matters just as much. In the clearest reports, the double materiality assessment is presented not merely as a table to tick off, but as an actual explanation of how the company reasons about its IROs and why these particular issues are material for the company. SEB is again a good example of a company that succeeds in this. In the description of the company’s DMA process, it explains how the analysis of IROs in the value chain stems directly from the core business, which makes the double materiality assessment feel like a natural part of how SEB understands its own role and impact rather than a standalone compliance document. 

In other reports the experience is different. The text is correct but feels distant, more like a legal document than a report that wants to convey its actual sustainability work. Formulations such as “the ambition is to”, “we are working towards”, or “planned to be implemented”, without time horizons or concrete actions, are common. They signal activity without actually committing to anything. Axfood goes in the opposite direction and is an example of how transparent target communication can look. The company openly reports when targets have not been met and explains why. It is a reminder that a sustainability report does not need to be a one-sided success story to be credible. 

Choose tables over narrative text

A clear shift in this year’s reports is that more companies have moved from describing policies and stakeholder dialogue in narrative form to presenting them in table format, or both. This makes the information more accessible and helps the reader quickly get an overview of which policies exist, what they cover and how they connect to the material topics. 

For policies, the shift is visible at companies such as Lindex, Equinor and Swedbank, all of which have added policy tables in this year’s report. The quality of the table varies, however. Tables sometimes list a policy’s name and relevance for each topic area, without explaining what the policy actually contains. A good policy table should give the reader sufficient information to understand the scope, not merely confirm that a policy exists.

For stakeholder dialogue we see the same movement towards table format, but depth varies. Norsk Hydro lists its stakeholders and describes engagement in narrative text, while Swedbank has also included a table to present its stakeholder dialogues. IF stands out by having moved from describing stakeholders’ perspectives on strategy and business model. Vestas is another example of a company that connects its stakeholders to strategy and business model. The clearest reports, such as Tele2, Hexagon Composites and Novo Nordisk, describe in table format how dialogue with stakeholder groups is conducted, what the purpose is, and what outcomes it has led to. 

At the same time as tables are gaining ground for policies and stakeholder dialogues, development is moving in the other direction for the double materiality assessment. Several companies have removed the matrix and now describe the DMA in narrative text. Vestas first describes at a high level how the DMA process was conducted, and then under each topic explains how that topic's IROs were identified and assessed. This means the reader gets both an overall picture and further depth. SEB also shows that narrative text can go a long way, as long as the description anchors the materiality assessment in the core business rather than describing a generic process. Ørsted, Assa Abloy and Vattenfall are among the companies that still use a matrix. 

Both approaches have their advantages. A matrix gives the reader a quick visual overview of how the company values different topics in relation to each other. Narrative text, on the other hand, provides more space to explain the reasoning behind the assessments and can make it easier to understand nuances that a matrix does not capture. The challenge with narrative text alone is that it places high demands on the reader to build a complete picture, while a matrix risks becoming more of a table to tick off rather than an explanation of how the company actually views the issues. The most informative solution often combines the two: a matrix that provides an overview and narrative text that explains the logic behind it. 

It is also worth noting that certain ESRS tables, such as E1-6 and S1-6, have a prescribed format that reporting companies are required to follow. The format is regulated in the application requirements precisely to enable comparability. When all reports present the same data in the same structure, it becomes easier for the reader to quickly find and compare information, which is part of the fundamental rationale for ESRS. 

Summary of best practice

This year’s analysis of CSRD reports shows that Nordic large-cap companies continue to mature, but that development is uneven and continued discrepancies exist. Companies reporting for the second year have improved on structure and terminology, but this does not always mean the report has become easier to read or more informative. Major challenges remain: IROs are not named consistently and the connection to policies, actions and targets falls short in many reports. Phase-in provisions are often communicated unclearly, and many reports remain difficult to read, extensive, and hard to absorb. At the same time, clear progress is visible where more companies are using tables to their advantage in reporting. The presentation of policies and stakeholder dialogues are good examples of this. Finally, design is receiving increasing attention and some reports stand out as well-structured and communicative. 

Below we summerise some best practice from our analysis: 

• Name your IROs and refer back to them consistently under each topic, with a clear connection to policies, actions and targets
• Disclose phase-in provisions early and collectively, preferably in table format
• Prioritise readability and clear communication
• Use tables or bullet lists for policies and stakeholder dialogues, and ensure they provide sufficient information

This year’s reports also serve as a reminder that maturity is not always visible in page count. Companies such as Ørsted, Assa Abloy and Vestas have shown that it is possible to deliver a complete and compliant sustainability report in under 70 pages. What they have in common is a consistent filter: every voluntary disclosure has been challenged with the question of whether it actually adds something for the reader. Repetitions have been removed and cross-references used instead, and the focus has shifted from narratively heavy descriptions towards metrics, targets and concrete evidence. 

This points to a different ambition than ticking off requirements. It is about treating the sustainability report as a communication document that reflects the company’s strategy and creates value for investors and other decision-makers, rather than a purely compliance-driven document. Ahead of the next reporting cycle, the question is worth asking: how long does your report actually need to be, and what is the purpose of each page? 

The Omnibus amendments – what happens now?

Ahead of financial year 2026, the question arises of how many companies will choose to apply the simplified standards, the so-called Omnibus amendments, which have not yet entered into force in Swedish law, or whether the majority will choose to remain with the current, more comprehensive requirements. On 17 April, the government’s inquiry presented its report (SOU 2026:27) with proposals for relief in the sustainability reporting requirements. According to the proposal companies with more than 1,000 employees and a net turnover exceeding SEK 4.9 billion are covered. Companies with 500-1,000 employees that reported for the financial year 2025 are proposed to no longer be subject to reporting obligations from 2025.

The proposal is out for consultation until 21 August, after which the remaining legislative process will determine whether the rules can enter into force in time for the 2026 annual reports. A government proposal is expected to be considered by the Swedish parliament during the autumn with a possible decision in December. The process regarding simplified ESRS standards and voluntary standards is proceeding in parallel at EU level. Both are expected to be applicable from financial year 2027, with an anticipated possibility of early application already for 2026. 

AVA Corporate Communications is a leading agency in financial communication, IR and sustainability reporting. We help listed companies navigate complex regulatory frameworks such as CSRD and Omnibus, from strategic frameworks and double materiality assessments to structuring, content production, design, and production of complete sustainability reports. Contact us to discuss how we can support you on the path to successful sustainability reporting. 

Companies included in the analysis: Assa Abloy, Atlas Copco, Axfood, Billerud, Equinor, Ericsson, Fagerhult, Hexagon Composites, Ica Gruppen, IF, Lindex, Länsförsäkringar, NetCompany, Nobia, Norsk Hydro, Novo Nordisk, Saab, SBAB, SEB, Swedbank, Tele2, Telia, Vattenfall, Vestas, Ørsted. 

¹ Phase-in refers to the disclosure requirements that are permitted to be introduced gradually. Read more about the phase-in provisions here.