Sustainability Insights

Assurance of First Wave CSRD Sustainability Statements

• First Time Adopters
• Auditing
• ESRS

The brief compares over 600 first-wave CSRD reports to provide insights into assurance and reporting quality in the first wave of implementation. Big Four firms and limited assurance dominate the first wave. Nearly 90% of engagements were conducted by the Big Four and more than 94% of reports provide only limited assurance. Qualified conclusions are rare: 1% of reports include qualifications mainly due to incomplete Scope 3 data, omitted sites, or omitted disclosures. Auditors frequently use Inherent Limitation (99%) and Other Matter (70%) paragraphs to highlight uncertainty and contextual limitations, while Emphasis of Matter (12%) paragraphs are rare.

National assurance practices also shape assurance reports, with distinct country-specific patterns. France leads in structure and transparency, using a prescribed three-part assurance format under the Haute Autorité de l'Audit (H2A) framework.

Regarding reporting quality data completeness remains uneven. In particular for Scope 3 emissions, comparability across firms and time is limited, and legal and definitional ambiguity in ESRS weakens clarity. Forward looking content like transition plans and targets enhance relevance but challenge verifiability.

The authors conclude with opportunities for improvement, such as clearer and more informative assurance reports, showcasing the advantages of the French sustainability assurance approach, and inclusion of Key Audit Matters sections. Additionally, the context on data quality, assumptions, and uncertainty ranges can be improved.

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