--- title: "2026 CSRD sustainability report: which mistakes to avoid?" description: "Generic materiality, vague targets, actions without a budget: the mistakes enforcers found in CSRD sustainability statements, and what to check before year-end." canonical: https://projetcelsius.com/en/blog/csrd-sustainability-report-2026-mistakes/ author: "Guillaume Pakula" datePublished: 2026-10-27 dateModified: 2026-10-27 language: en translationOf: https://projetcelsius.com/blog/rapport-durabilite-2026-erreurs-a-eviter/ --- # 2026 CSRD sustainability report: which mistakes to avoid? **Author**: Guillaume Pakula **Published**: 2026-10-27 **Section**: Regulation **Canonical URL**: https://projetcelsius.com/en/blog/csrd-sustainability-report-2026-mistakes/ **French original**: https://projetcelsius.com/blog/rapport-durabilite-2026-erreurs-a-eviter/ **Source**: Projet Celsius (https://projetcelsius.com/en/), a climate strategy consultancy of engineers and PhDs based in Paris and Marseille. > The mistakes to avoid in a **2026 sustainability report** are the ones enforcers have already found: a double materiality assessment described in generic terms, vague climate targets, actions without a budget and risks missing from the rest of the annual financial report. On **13 October 2026**, ESMA made them its enforcement priorities for financial year 2026, and France's AMF relayed them. They can be checked on the draft report, **before the 31 December year-end**. ## Key takeaways - Enforcers will look first at **double materiality and the link between actions and targets**. - In 2025, **30% of the companies reviewed** in Europe received an enforcement action. - Climate accounts for **40% of enforcement actions** on reports prepared under the ESRS. - In France, the first wave **still reports on 2026**, as no transposing law has been passed. On **13 October 2026**, the European Securities and Markets Authority (ESMA) published the points that regulators will examine first in reports for financial year 2026. For the sustainability statement, it sets **2**: the double materiality assessment, and the link between sustainability matters, actions, targets and metrics, checked this year on **climate and the workforce**. The Autorité des marchés financiers (AMF), which supervises listed companies in France, [relayed them the following day](https://www.amf-france.org/fr/actualites-publications/actualites/preparation-des-prochains-etats-de-durabilite-lamf-attire-lattention-des-societes-cotees-sur-les). These priorities reflect the shortcomings found in the first reports, published in 2025 on financial year 2024. They are aimed first at companies in the first wave of the [Corporate Sustainability Reporting Directive (CSRD)](https://projetcelsius.com/en/blog/esrs-e1-ghg-inventory-after-omnibus/), which are preparing their **third report**. The sections below set out who reports on 2026 and how enforcement works, then what to check before year-end. ## Who must report on 2026, and what does the Omnibus change? In France, as at 27 October 2026, **the whole first wave** must publish a sustainability statement on financial year 2026. It comprises large listed companies, banks and insurers with more than 500 employees, which have reported since financial year 2024, and the parent companies of large groups with the same profile. ### France has not changed the timetable for the first wave The applicable law is still **the ordinance of 6 December 2023**, which transposed the CSRD into French law. Its timetable has been amended only once, by the law of 30 April 2025: the other large companies, the second wave, will report from **financial year 2027** and listed SMEs from 2028, while the first wave keeps its original timetable. ### An exemption passed by the Senate, not yet by the National Assembly The [Omnibus Directive of 24 February 2026](https://eur-lex.europa.eu/eli/dir/2026/470/oj) limits the CSRD to companies that exceed both **1,000 employees and €450 million** in net turnover, from financial year 2027. It also allows Member States to **exempt for 2025 and 2026** first-wave companies that remain below either of these 2 thresholds. France must transpose it by 19 March 2027 at the latest. The French bill adapting national law to EU law, which would open this exemption from 2026, was [passed by the Senate](https://www.senat.fr/leg/tas25-063.html) on 18 February 2026. Sent to the [National Assembly](https://www.assemblee-nationale.fr/dyn/17/dossiers/DLR5L17N53140) on 20 February, it was referred to committee but **had not been debated in plenary** as at 27 October 2026. Its thresholds are also left to a decree, which has not been issued. Until the law and its decree are published, a first-wave company below the thresholds **remains required to publish** on 2026. A company above the 2 thresholds reports in all cases, and the rest of this article is addressed to it first. A company that leaves the scope will, above 500 employees, fall back under [the BEGES (bilan d'émissions de gaz à effet de serre), France's mandatory greenhouse gas emissions report](https://projetcelsius.com/en/blog/beges-france-mandatory-ghg-report/). ## Who enforces sustainability reporting, and how? The sustainability statement is part of a listed company's annual financial report. Once published, it therefore comes under the same enforcers as the financial statements: **the AMF in France**, which applies priorities set each year with its European counterparts. Investors read it too, and use it for [their own financed emissions calculations](https://projetcelsius.com/en/blog/pcaf-financed-emissions-investment-funds/). ### The European priorities for 2026 [ESMA's statement of 13 October 2026](https://www.esma.europa.eu/sites/default/files/2026-10/ESMA32-2064178921-9738_Statement_-_2026_European_Common_Enforcement_Priorities__ECEP_.pdf) sets **2 for the sustainability statement**. The first asks companies to keep improving their materiality assessment. The second concerns consistency between material matters, policies, actions, targets and metrics. It applies to all topics, but enforcers will check it in 2026 on **climate and own workforce**, the 2 most mature. > **What is double materiality?** It is the assessment that decides what the report contains. A matter is included if it is **material from an impact perspective**, because the company has a significant effect on people or the environment, or **from a financial perspective**, because it creates a risk or an opportunity for the company. The statement also points out that financial year 2026 is a transition year. Companies choose between [3 versions of the European Sustainability Reporting Standards (ESRS)](https://projetcelsius.com/en/blog/revised-esrs-2026/), and must **state which one they apply**, preferably in the basis for preparation of their report. The EU taxonomy has no priority of its own this year, but enforcers continue to check it. ### Enforcement by the AMF in France On 14 October 2026, the AMF drew listed companies' attention to these priorities and published **an unofficial French translation**. Its recommendations for the 2026 year-end cover the financial statements and **refer to ESMA for sustainability**. On 4 November 2026, [an AMF webinar](https://www.amf-france.org/fr/actualites-publications/actualites/webinaire-preparer-son-reporting-csrd-eclairages-de-lamf-sur-les-etats-de-durabilite-2025-des) will present its findings on the 2025 sustainability statements, in particular on materiality and climate reporting. Enforcement takes place **after publication**. On financial statements, the AMF completed 49 reviews between October 2025 and September 2026. Of the companies selected in 2026, about 85% were chosen through a risk analysis. Each recommendation in its end-of-review letters is followed up at the next year-end. For sustainability, the AMF confirmed in January 2026 what it calls a **pragmatic approach**, based on dialogue with companies: it will apply ESMA's guidelines on the supervision of this information only once the rules have stabilised across the EU. ### What happens after an error is found A review that identifies a material misstatement leads to an enforcement action. In Europe, in 2025, this was almost always **a correction in the next report**. The AMF may also order **corrective or additional disclosures**, and it maintains its reviews and investigations where [greenwashing](https://projetcelsius.com/en/blog/greenwashing-test-3-questions/) is suspected. A target labelled "1.5°C-compatible" without evidence invites that criticism, as does an unsubstantiated [environmental claim](https://projetcelsius.com/en/blog/banned-environmental-claims-eu/). ## What mistakes did enforcers find in the first CSRD reports? 2025 was the first year in which regulators reviewed reports prepared under the ESRS. [ESMA's report of 7 May 2026](https://www.esma.europa.eu/sites/default/files/2026-05/ESMA32-2064178921-9413_Report_on_2025_Corporate_reporting_enforcement_and_regulatory_activities.pdf) draws European figures from these reviews, and the AMF published its own study of the first French reports. ### The European picture for 2025 About **2,000 listed companies** in Europe were within the scope of enforcement. Regulators examined the content of the sustainability statements of 367 of them, under the new standards or the former regime, and took action against **109 companies, or 30%**. In **103 of the 109 cases**, the action required a correction in the next report. In reports prepared under the ESRS, **40% of actions** concerned climate (standard E1) and 36% the general disclosures of ESRS 2, which cover the materiality assessment and strategy. ESMA attributes the weight of climate to the maturity of the topic, which makes enforcers more demanding. ### What enforcers found across Europe Building on the priorities it had set for the 2024 reports, ESMA arranged for a risk-based sample of companies to be examined. Most of them describe their materiality assessment correctly, but several shortcomings recur: - The description of the double materiality process often remains **generic**: it repeats the steps in the standards without saying how the company adapted them to its own situation. - Matters are named in **in-house vocabulary**, different from that of the ESRS, which makes it impossible to trace the topical disclosures linked to them. - **Links with the financial statements** are often missing, and the scope of the sustainability statement sometimes differs from that of the consolidated financial statements. - Cross-references to other parts of the annual report do not always meet the conditions set by the standards, and sometimes impair readability. In a sample of 91 companies, an ESMA study of October 2025 found that **about 6 in 10** met the objective of the disclosure requirement that describes the materiality assessment process. ### What the AMF found in France [The AMF's October 2025 study](https://www.amf-france.org/sites/institutionnel/files/private/2025-10/amf_study_csrd_reporting_the_way_forward_2025.pdf) covers 20 first reports from French listed companies with more than 1,000 employees. It finds materiality assessment results that are **inconsistent within the same sector**, which complicates the comparisons made by investors and [rating platforms](https://projetcelsius.com/en/blog/does-ecovadis-replace-a-carbon-footprint/). It also notes that the financial effects of action plans are hard to quantify. Across 91 companies in the CAC 40 and SBF 120, almost all reports received an unqualified assurance conclusion, but **1 report in 5** carried an observation from the assurance provider on the double materiality process. > A sustainability statement stands up to enforcement when each material matter leads to an action, its budget and a quantified target. ## What should you check before the 31 December year-end? The list below follows, point by point, what ESMA's statement asks for financial year 2026. It is run on the draft report, **before year-end**, while there is still time to complete a data point or reword a target. ### Double materiality The materiality assessment is the foundation for the rest of the report, and enforcers return to it every year: - Positive and negative impacts are assessed **with the same rigour** and described in the same level of detail, which ESMA does not always find. - The **materiality thresholds** for impacts are disclosed, especially when the company does not use the same ones for positive and negative impacts. - The assessment covers own operations **and the value chain**, upstream and downstream, as [a complete Scope 3](https://projetcelsius.com/en/blog/scope-3-emissions-guide/) does for emissions. - The process is described concisely and **specifically for each topic**: workforce matters are not identified in the same way as climate matters. - A matter is classified as "entity-specific" only **after ruling out** every ESRS category, so that the report remains comparable. ### Targets Targets make it possible to track progress from one year to the next, and ESMA devotes the longest part of its statement to them: - Each target is **measurable, time-bound and outcome-oriented**, with its own methodology; ESMA suggests a table rather than a paragraph that mixes several targets. - A reduction target that **does not cover the whole greenhouse gas inventory** explains why, for example when it leaves out [part of Scope 3](https://projetcelsius.com/en/blog/is-scope-3-reporting-mandatory/). - The words "science-based" or "1.5°C" are used only when stating **whether and how** the target meets them, whether it refers to [a Science Based Targets initiative (SBTi) pathway](https://projetcelsius.com/en/blog/sbti-for-industrial-smes/) or to [France's national low-carbon strategy (SNBC)](https://projetcelsius.com/en/blog/snbc-3-business-obligations/). - Targets are given **in absolute values**, not only as intensities, and gross targets are kept separate from targets net of [offsetting](https://projetcelsius.com/en/blog/carbon-neutral-claims-what-companies-can-say/). - A target from the previous year is reported as **met, missed or abandoned**, and any change of base year or baseline value is explained, which is the first thing [a verifier of climate commitments](https://projetcelsius.com/en/blog/climate-commitments-third-party-verification/) looks at. - For the workforce, general commitments are not presented as targets: a target carries a value, a date and a material matter. ### Actions and their budget Each key action states how it serves the policy objective, and what **financial resources**, capital or operating expenditure, are allocated to it now and in future. A key action without a budget calls for an explanation, and [a transition plan](https://projetcelsius.com/en/blog/climate-transition-plan-requirements/) without quantified investment does not hold up against the financial statements. A material matter **with no policy or action** is disclosed as such. An action that covers only part of the matter says so too: a plan that addresses transition risks without [physical risks](https://projetcelsius.com/en/blog/pnacc-3-business-adaptation/), for example, or the company's own sites without its value chain. ### Consistency with the financial statements The sustainability risks identified in the report must **appear in the risk chapter** of the annual financial report, and ESMA has found discrepancies between the 2. The current financial effects of material matters are disclosed. The AMF adds a specific case: **renewable power purchase agreements** are presented the same way in the sustainability statement and in the notes to the financial statements. Finally, a 2026 report that applies the revised standards or their reliefs **flags what is no longer comparable** with 2025. Restated prior-year figures are labelled as such. ## Who provides assurance on the report before publication? Before publication, the report goes to an assurance provider, whose **opinion is published with it**. This is the first external reading, and its observations already most often concern the double materiality process. ### Assurance in France in 2026 In France, the sustainability statement is certified by a **statutory auditor (commissaire aux comptes) or an accredited independent third-party organisation (organisme tiers indépendant)**, at the company's choice, on a **limited assurance** basis. No European assurance standard has yet been adopted: the Omnibus Directive postponed its adoption to 1 July 2027 and removed the planned move to reasonable assurance. In the meantime, assurance providers follow [the guidelines of the Haute Autorité de l'audit](https://h2a-france.org/wp-content/uploads/2026/01/H2A-CSRD-Lignes-directrices-Certification-durabilite-Janvier-2026.pdf), France's audit oversight authority, updated in January 2026. Their report concludes with an opinion of conformity, a qualified opinion, an adverse opinion or a statement that no conclusion can be reached. No XBRL tagging of the sustainability statement is required for 2026, as no European rules have been adopted. The approach is close to that of [a third party verifying a Bilan Carbone® (the French carbon accounting method)](https://projetcelsius.com/en/blog/in-house-carbon-footprint-third-party-verification/). ### What changes for financial year 2027 [The revised ESRS](https://projetcelsius.com/en/blog/revised-esrs-2026/) apply to financial years beginning on or after 1 January 2027. ESMA encourages companies to prepare now, with one substantive change: the company **no longer discloses non-material information**, except in specified cases. It also notes that many targets reach **their 2030 deadline**. A company that knows it will not meet its own must say so without waiting, rather than in the deadline year. The scope of companies covered will depend on the transposition of the Omnibus, which [France's 2027 presidential election](https://projetcelsius.com/en/blog/france-2027-election-environmental-obligations/) could delay. At Projet Celsius, we consider that ESMA's 2 priorities are checked **against the evidence**. A report that links each material matter to a funded action and a quantified target, tracked with the same method from one year to the next, stands up to enforcement, even when plainly written. The useful review therefore takes place before year-end, matter by matter: [the reduction action](https://projetcelsius.com/en/blog/how-to-reduce-company-carbon-footprint/), its budget, its target, the metric that tracks it, then the same line in the risk chapter. For climate, it starts with [the emissions inventory](https://projetcelsius.com/en/blog/esrs-e1-ghg-inventory-after-omnibus/) on which the targets rest. ## Key takeaways - For financial year 2026, enforcers will look first at **the double materiality assessment** and the link between matters, actions, targets and metrics, on climate and the workforce. - In 2025, **30% of the companies reviewed** in Europe received an enforcement action, almost always a correction to make in the next report. - Enforcers mainly find **a generic materiality process**, vague targets and missing links with the financial statements. - In France, **the whole first wave reports on 2026** until the law transposing the Omnibus Directive is passed and its decree published. - The check is done **before the 31 December year-end**, matter by matter, then compared with the risk chapter of the annual financial report. To choose which version of the standards to apply this year, [our article on the revised ESRS](https://projetcelsius.com/en/blog/revised-esrs-2026/) compares the 3 options, and [our CSRD guide](https://projetcelsius.com/en/blog/csrd-2026-who-is-in-scope-after-omnibus/) explains what changes for SMEs asked for data by their customers. ## Frequently asked questions ## Frequently asked questions ### What are ESMA's enforcement priorities for 2026? They are the points that ESMA and national regulators, including the AMF in France, will examine first in annual financial reports for financial year 2026. Published on 13 October 2026, they set 2 for the sustainability statement: the double materiality assessment, and consistency between matters, policies, actions, targets and metrics, checked on climate and own workforce. ### Does the AMF review sustainability statements? Yes. The sustainability statement is part of the annual financial report of listed companies, which the AMF reviews after publication. It applies ESMA's common priorities and, according to its January 2026 priorities, proceeds pragmatically, through dialogue with companies. It may order corrective or additional disclosures, and it maintains its reviews where greenwashing is suspected. ### Must a company with fewer than 1,000 employees report on 2026 in France? Yes, if it belongs to the first wave of the CSRD. As at 27 October 2026, France has not transposed the Omnibus Directive, which allows first-wave companies below 1,000 employees or €450 million in turnover to be exempted for 2025 and 2026. The bill that would open this exemption was passed by the Senate in February 2026 but has not yet been examined in plenary by the National Assembly, and its decree setting the thresholds has not been issued. ### Which version of the ESRS applies to financial year 2026? Delegated Regulation (EU) 2026/1563 leaves 3 options for a financial year beginning in 2026: the 2023 ESRS as amended in 2025, the revised ESRS applied early, or the 2023 ESRS with 8 reliefs listed exhaustively. ESMA asks companies to state clearly which version they use, preferably in the basis for preparation of the report, and to flag data that are no longer comparable. ### Who provides assurance on the sustainability statement in France? A statutory auditor or an accredited independent third-party organisation, at the company's choice, which issues a limited assurance opinion. In the absence of a European assurance standard, expected by 1 July 2027 at the latest, assurance providers in France follow the guidelines of the Haute Autorité de l'audit, updated in January 2026. The Omnibus Directive removed the planned move to reasonable assurance. ### Does the sustainability statement have to be tagged in XBRL? Not for financial year 2026. The Omnibus Directive provides that companies are not required to tag their sustainability information until tagging rules have been adopted in the European Single Electronic Format (ESEF) Regulation, which is not the case as at 27 October 2026. The tagging that ESMA checks in 2026 concerns the financial statements. ## Sources - **ESMA**: [statement ESMA32-2064178921-9738](https://www.esma.europa.eu/sites/default/files/2026-10/ESMA32-2064178921-9738_Statement_-_2026_European_Common_Enforcement_Priorities__ECEP_.pdf), "European common enforcement priorities for 2026 corporate reporting", 13 October 2026, section 2 and section 4; [report ESMA32-2064178921-9413](https://www.esma.europa.eu/sites/default/files/2026-05/ESMA32-2064178921-9413_Report_on_2025_Corporate_reporting_enforcement_and_regulatory_activities.pdf) on 2025 enforcement, 7 May 2026, pages 21 to 27; [study ESMA32-846262651-5288](https://www.esma.europa.eu/sites/default/files/2025-10/ESMA32-846262651-5288_Fact_finding_on_materiality_disclosures_in_sustainability_statements.pdf) on materiality, 14 October 2025. - **AMF**: [news item of 14 October 2026](https://www.amf-france.org/fr/actualites-publications/actualites/preparation-des-prochains-etats-de-durabilite-lamf-attire-lattention-des-societes-cotees-sur-les) and [unofficial French translation of ESMA's priorities](https://www.amf-france.org/sites/institutionnel/files/private/2026-10/ecep_2026_sur_le_reporting_de_durabilite_-_traduction_francaise.pdf); [recommendation DOC-2026-06](https://www.amf-france.org/fr/reglementation/doctrine/doc-2026-06) of 13 October 2026, sections 1.2 and 3.2; [announcement of the webinar of 4 November 2026](https://www.amf-france.org/fr/actualites-publications/actualites/webinaire-preparer-son-reporting-csrd-eclairages-de-lamf-sur-les-etats-de-durabilite-2025-des); ["Corporate sustainability reporting: the way forward"](https://www.amf-france.org/sites/institutionnel/files/private/2025-10/amf_study_csrd_reporting_the_way_forward_2025.pdf), October 2025; [2026 action and supervision priorities](https://www.amf-france.org/sites/institutionnel/files/private/2026-01/amf_priorites-daction-et-supervision-2026.pdf), January 2026, action 9. The AMF pages are in French, except the way forward study. - **EU texts**: [Directive (EU) 2026/470](https://eur-lex.europa.eu/eli/dir/2026/470/oj) of 24 February 2026, known as the Omnibus; [Delegated Regulation (EU) 2026/1563](https://eur-lex.europa.eu/eli/reg_del/2026/1563/oj) of 3 July 2026 (revised ESRS), Article 2. - **French texts**: [Ordinance No. 2023-1142 of 6 December 2023](https://www.legifrance.gouv.fr/loda/id/JORFTEXT000048519395/), Article 33; [Law No. 2025-391 of 30 April 2025](https://www.legifrance.gouv.fr/eli/loi/2025/4/30/2025-391/jo/texte), Article 7; [French Monetary and Financial Code, Article L. 621-18](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000033612031); bill adapting French law to EU law, [text passed by the Senate on 18 February 2026](https://www.senat.fr/leg/tas25-063.html), Article 9, and [National Assembly file](https://www.assemblee-nationale.fr/dyn/17/dossiers/DLR5L17N53140), consulted on 27 October 2026. The Légifrance, Senate and National Assembly pages are in French. - **Assurance**: Haute Autorité de l'audit, [guidelines on the engagement to certify sustainability information](https://h2a-france.org/wp-content/uploads/2026/01/H2A-CSRD-Lignes-directrices-Certification-durabilite-Janvier-2026.pdf), January 2026 (in French).