Throughout 2025, significant developments occurred in the field of sustainability reporting. On one hand, the Corporate Sustainability Reporting Directive (CSRD) entered into force and was transposed into Italian law through Legislative Decree No. 125 of 6 September 2024. In parallel, the European Commission presented the so-called "Omnibus" proposal (first package adopted in April 2025), aimed at simplifying EU sustainability reporting regulations.
At the same time, large companies already subject to the NFRD – the so-called Wave 1 – began publishing their sustainability statements for the 2024 financial year, in line with the European Sustainability Reporting Standards (ESRS). The objective is to offer greater transparency and awareness to stakeholders on environmental, social and governance (ESG) topics.
EFRAG, in its recent analysis of sustainability statements published in 2025, highlighted several ongoing challenges: the interpretation of standards, the consistency of the information provided, and the efficiency of reporting processes remain critical issues in the initial implementation phase.
Scope of the analysis
EFRAG’s analysis covers sustainability statements for the 2024 fiscal year, prepared in accordance with the CSRD and collected as of April 20, 2025. A Generative AI-based approach was used to support this analysis, with results subsequently verified manually on a selected sample. In parallel, a second analytical stream was developed based on a series of case studies: companies with particularly relevant elements were selected, anonymized, and analyzed individually.
Within the European context, Italy ranks fourth in terms of the number of CSRD-aligned sustainability reports, with 57 non-financial companies (classified by NACE code) and 8 financial institutions (including banks, insurers, and other financial entities).
Focus on Italian non-financial companies
Within the analyzed scope, the leading Italian non-financial companies that published CSRD-aligned sustainability statements largely belong to the manufacturing sector (31 companies). This is followed by the information and communication sector (7), professional, scientific and technical activities (7), and the electricity, gas, steam and air conditioning supply sector (6).
The themes analyzed by EFRAG include:
- Average number of report pages: companies in the energy sector (electricity, gas, steam, air conditioning) stand out with the longest reports, averaging 157 pages, followed by the manufacturing sector (137 pages) and professional, scientific and technical activities (104 pages). EFRAG’s analysis indicates that report length is strongly influenced by sectoral and geographical context, which shapes both reporting expectations and practices.
- Materiality of ESRS topical standards: on average, Italian companies identified 7 ESRS topical standards as material. The most frequently reported topics include: climate change (E1, 96% of companies), own workforce (S1, 96%), business conduct (G1, 93%), circular economy (E5, 79%), workers in the value chain (S2, 77%), consumers and end users (S4, 77%), and pollution (E2, 46%). At the sub-topic level, the following elements emerge: a. For climate change, the most commonly reported sub-topics are mitigation and energy use (88%), followed by climate change adaptation (72%); b. In the area of own workforce, working conditions are the most relevant sub-topic (91%); c. Regarding business conduct, the most material sub-topic is corruption and bribery (79%), followed by supplier relationships (56%) and corporate culture (54%).
- Stakeholders involved in the double materiality assessment are primarily internal stakeholders, followed by suppliers, customers, and investors.
- Focus on environmental aspects: only 21% of companies declared having a climate transition plan (significantly below the European average of 56%); 12% reported using an internal carbon price (ICP) to attribute costs to GHG emissions (compared to a 24% European average); and 19% disclose biodiversity metrics (vs. a European average of 32%). The main Italian companies disclosing this information belong to the energy sector (electricity, gas, steam, air conditioning).
- Adequate wage in the European Economic Area: 97% of Italian companies declare that their workers receive adequate remuneration (as required by relevant regulations).
Conclusions
Although the regulatory framework is still evolving, the publication of the first sustainability statements aligned with the European Sustainability Reporting Standards (ESRS) marks a significant step toward increased transparency on environmental, social and governance (ESG) issues.
The analysis highlights that Italian companies have clearly identified key material topics, but also shows that the effective integration of ESG factors into corporate decision-making processes is still at an early stage. In particular, content inconsistency, limited adoption of climate transition plans, and sparse use of advanced tools such as internal carbon pricing signal ample room for improvement.
To generate real impact, it will be crucial for companies to strengthen their internal processes for ESG data collection, analysis and communication, thus transforming reporting into a strategic tool that supports business decision-making and stakeholder trust.