Sustainability Insights
Anticipated Financial Effects Disclosures under ESRS
- Maximilian A. Müller
- Maximilian Terboven
- Niclas Höhne
- Anticipation
- Financial Effects
- ESRS
We have analyzed Anticipated Financial Effects (AFE) disclosures under the ESRS and find that they are still uncommon in first-wave CSRD reporting. In a sample of 750+ first-wave CSRD reports (FY2024), only about 16% of firms voluntarily disclose at least one AFE disclosure requirement, despite these topics often being assessed as financially material.
Where firms do report AFEs, disclosure is concentrated in climate (ESRS E1-9), which shows both the highest uptake and comparatively stronger reporting quality than other environmental AFE requirements (pollution, water, biodiversity, circular economy). However, overall disclosure quality varies widely and is frequently weakly substantiated: a notable share of AFE disclosures is unspecific, lacks a clear risk assessment, or states that no material risks exist. Quantification and methodological transparency remain rare; most disclosures are narrative-only, and only a small minority explains the methods used to assess AFEs.
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