--- url: 'https://kshuttle.io/en/efrag-2026-esrs-report-csrd-reporting-maturity/' title: 'ESRS: what EFRAG’s 2026 report really says about corporate maturity ' author: name: Ambre Thevenon url: 'https://kshuttle.io/en/author/ambre-thevenon/' date: '2026-07-08T08:18:05+00:00' modified: '2026-07-08T08:18:05+00:00' type: post summary: 'EFRAG’s State of Play 2026 report provides one of the clearest views yet of how companies are applying ESRS in practice. Beyond compliance, the report raises a key question: are companies only learning to publish sustainability information, or are they starting to manage what they declare as material?' categories: - News - Sustainability image: 'https://kshuttle.io/wp-content/uploads/2026/07/EFRAG-1.png' published: true --- # ESRS: what EFRAG’s 2026 report really says about corporate maturity  CSRD reporting is entering its second year. With it, a first layer of field evidence is starting to emerge. In its *[State of Play 2026](https://www.efrag.org/sites/default/files/media/document/2026-07/EFRAG_State%20of%20Play%202026_vShared_Layout%20checked%20-%20DD.pdf?utm_medium=email&_hsmi=426607954&utm_content=426607954&utm_source=hs_email)* report, [EFRAG](https://kshuttle.io/en/esrs-set-2-what-changes-for-csrd-reporting/) analyses more than 900 sustainability statements prepared under the ESRS. The purpose is not to comment on regulation in theory, but to observe what companies are actually producing: the topics they consider material, the data they disclose, the targets they set, and the blind spots that remain. The conclusion is more nuanced than simply saying that companies are progressing. Yes, **ESRS reporting is becoming more stable.** Yes, practices are becoming more consistent. A more important question now emerges: **are companies merely learning how to publish more sustainability information, or are they starting to manage what they declare as material?** ## 1. “ESRS reporting is no longer a blank page. It is not yet a reflex.” The first key message from EFRAG’s report is **continuity**. Companies are no longer starting from scratch. After the first year of application, the main contours of [ESRS](https://kshuttle.io/en/csrd-sustainability-reporting-2026/) reporting are beginning to stabilise: the same standards are widely considered material, the same topics dominate, and the overall structure of sustainability statements is becoming more familiar. Climate change, own workforce and business conduct remain the core pillars of sustainability reporting. Companies are getting better at understanding the framework, its requirements, its rituals and its critical checkpoints. This stability does not mean that the subject is settled. It tells a different story: the CSRD is beginning to move beyond the initial shock of regulatory implementation. Companies are learning how to produce ; how to organise their disclosures and how to speak ESRS. The question is now: “how do we make this report useful, readable, traceable and manageable?” This is where the second stage of maturity begins. ## 2. “Double materiality is now installed. The question is what companies do with it.” According to EFRAG, a large majority of companies **updated their [Double Materiality](#q&a-double-materiality) Assessment for FY2025**. This is an important signal: the DMA is no longer just a first-year exercise completed once in response to a regulatory requirement. It is becoming a living process. Companies are adjusting, recalibrating and refining their assessments. Some are correcting inconsistencies. Others are reviewing thresholds, scopes or IROs following internal changes, perimeter evolutions or acquisitions. Behind this movement, one question remains central: **is double materiality being used as a real management tool, or only as an entry point into the reporting process?** This is where the current ambiguity lies. Identifying material topics is one thing. Connecting them to targets, action plans, responsibilities, reliable data and evidence is another. The DMA cannot remain a static map locked inside a document. It needs to become a governance mechanism. --- ## 3. “Not everything material is being managed yet.” This is probably one of the most interesting figures in the report. **Companies identify an average of 6.4 ESRS topics as material.** Yet they only set measurable targets for 3.3 of them. In other words, nearly half of material topics are not yet covered by quantified targets. This gap says a lot about the current maturity of sustainability reporting. On the one hand, companies are making progress in identifying their impacts, risks and opportunities. They are becoming better at saying what matters ; at mapping their sustainability issues ; at structuring their disclosures. On the other hand, the operational translation remains incomplete. A topic can be declared material without yet being managed through a clear target, a deadline, an owner, a monitored data point or a decision-making process. This is precisely where the CSRD changes in nature. It is no longer only a publication exercise. It becomes a test of consistency between what a company declares as important and what it is actually able to monitor over time. --- ## 4. “Climate still dominates. Climate maturity remains uneven.” Unsurprisingly, climate remains the dominant topic in ESRS reporting. Almost all companies analysed by EFRAG consider climate change to be material. The report also shows clear progress in the adoption of climate transition plans. This is a positive development. The figure alone, however, is not enough. Declaring a climate transition plan does not necessarily mean having a robust, documented, aligned and monitored trajectory connected to business decisions. EFRAG highlights the gap between companies that disclose a climate transition plan and those that explicitly disclose near-term and long-term decarbonisation targets compatible with a 1.5°C pathway. In other words: **climate planning is progressing, without all companies reaching the same level of precision.** This type of gap will become increasingly visible to auditors, investors, regulators and stakeholders. --- ## 5. “The data exists. It is still often too aggregated.” EFRAG’s report also shows progress on non-climate environmental topics: pollution, water, biodiversity and circular economy. The data disclosed, however, remains very often aggregated at group level. This is a key point. For some topics, especially water, biodiversity or pollution, location matters. A consolidated global figure can be useful to provide an overview. It is not always enough to understand real exposure, local impacts or operational priorities. This is the challenge of granularity. How far should companies disaggregate? At what level should they disclose? How should they balance readability, materiality, collection effort and the relevance of information? These questions will be central to the next stages of ESRS evolution. They already matter in information systems. Before a company can publish a data point, it must be able to collect it at the right level, qualify it, connect it to an entity, a site, an activity, a period, a source and an audit trail. --- ## 6. “Governance is entering the hard part.” EFRAG’s 2026 edition also introduces a more structured view of governance disclosures, particularly through supplier relationship management. A majority of companies now mention ESG criteria in supplier selection. These criteria, however, are still often expressed through supplier codes of conduct or high-level commitments. Operational integration is less common: supplier scoring, corrective action plans, exclusion mechanisms, long-term monitoring and ESG performance management remain more limited. The same applies to SME-specific payment terms, which are still rarely disclosed. The reason is interesting: this is not only a question of willingness. It is also a question of systems. Many companies do not yet have ERP systems or supplier master data capable of easily identifying SMEs, segmenting payment terms or producing usable information at the right level of detail. Sustainable governance is therefore not only a policy issue. It is also a data infrastructure issue. --- ## 7. “The next step is not more reporting. It is useful reporting.” Through this report, EFRAG is not saying that companies are failing. It shows that they are somewhere in the middle of the journey. The first step was to publish under ESRS. That step is now being installed. The second step is to make sustainability information reliable, explainable, manageable and usable – more demanding. It requires connecting Sustainability, Finance, Risk, Procurement, HR, Legal and Operations teams ; moving away from scattered files. It requires structuring data, controls, workflows, responsibilities and evidence. At kShuttle, this is precisely our conviction: CSRD reporting is not only about producing a sustainability statement. It requires companies to build a long-term capability to manage non-financial information. **With [CSR Insight on ExRP®](https://kshuttle.io/en/solution/csrd-compliance/), we help organisations structure ESG data collection campaigns, improve data reliability, secure controls, document decisions and prepare traceable, auditable and usable sustainability reporting.** ## Q&A – EFRAG State of Play 2026 and ESRS reporting maturity What does EFRAG’s State of Play 2026 report analyse? EFRAG’s State of Play 2026 report analyses how companies are applying ESRS in the second year of CSRD reporting. It looks at the structure of sustainability statements, material topics, double materiality practices, ESG targets, climate disclosures, social indicators and governance-related information. What is the main takeaway from the report? The main takeaway is that ESRS reporting is stabilising, but the shift from reporting to management remains incomplete. Companies are becoming better at identifying and disclosing material topics, yet not all of these topics are supported by targets, indicators, responsibilities or monitoring mechanisms. Why does double materiality remain central under the ESRS? Double materiality defines the scope of sustainability reporting. It helps companies identify the most relevant impacts, risks and opportunities for the business and its stakeholders. Its value depends on whether it can then feed decision-making, action plans and long-term management. What does the report say about ESG targets? EFRAG highlights a gap between the number of material topics identified by companies and the number of topics covered by measurable targets. This shows that reporting maturity is not only about the ability to disclose information, but also about the ability to translate material issues into operational management. Why does ESG data remain a major challenge? ESRS reporting relies on large volumes of data, often produced by different teams, entities, countries and systems. To be useful, ESG data must be reliable, traceable, contextualised, controlled and available at the right level of granularity. How does kShuttle support companies with CSRD reporting? With CSR Insight on ExRP®, kShuttle helps organisations structure their ESG and CSRD reporting processes: data collection campaigns, validation workflows, controls, audit trail, data consolidation, indicator monitoring and preparation of sustainability reporting.