The year 2026 is at least as interesting in terms of sustainability reporting as 2025 was. Since the turn of the year 2026, Finnish entities belonging to the ‘first wave’ of sustainability reporting have published their second sustainability report under the Finnish Accounting Act (hereinafter also ‘CSRD report’). What changed in reporting, or did anything change?

As a follow-up to our 2025 study on the Finnish first-wave sustainability reports, we have analysed CSRD reports for the second reporting year. The review focused on the same group of entities as the 2025 study, comprising 95 companies. Of these, 90 also prepared a second-year sustainability report and are covered in this report.

Below, we share our key observations from the second year of reporting and compare them with the observations from the (more extensive) first-year dataset.

Observations

1. Title of the CSRD report

Almost three-quarters of the reports analysed by us (72%) were titled sustainability reports (‘kestävyysraportti’). This title corresponds to the terminology used in the Finnish Accounting Act (title of chapter 7 of the Finnish Accounting Act). One quarter of the reports (25%) were named sustainability statements (‘kestävyysselvitys’), which is the term used in the ESRS standards. The rest of the reports (3%) were titled consolidated sustainability reports (‘konsernikestävyysraportti’), which also corresponds to the terminology used in the Finnish Accounting Act (title of chapter 7, section 19 of the Finnish Accounting Act).

All reports were prepared on a consolidated basis, i.e., at the group level, although only a few reports were named as consolidated sustainability reports (‘konsernikestävyysraportti’).

The report naming convention was in line with the practice followed in the first reporting year.

2. Report length

The length of the reports varied from just over 20 pages to 170 pages. The average length of a report was 73 pages.

Particularly within the financial sector, EU taxonomy disclosures may considerably impact the length of the CSRD report. Excluding financial sector entities, the range of report lengths was significantly narrower, from just over 20 pages to about 120 pages. In this group, the average length of a report was 71 pages.

The average length of the reports did not change compared to the previous year. However, a clear change was observed in the range of report lengths: in the previous year, the range across the full dataset was just over 20 to about 260 pages.

The significant reduction in the range is partly explained by the simplifications of the EU taxonomy disclosures that entered into force in January 2026, which have been applied in particular in the financial sector.

The principles related to sustainability reporting, the specifics of the reporting entity’s business, the industry and the number of material sustainability matters have an understandable impact on the length of the sustainability reports. No two reporters are exactly alike. How did the second year of reporting manifest at the level of individual reports? The number of pages in the CSRD report increased in more than half of the reports (52%). In the remaining reports, the number of pages either decreased (42%) or remained unchanged compared to the previous year (6%).

3. Double materiality principle

At the heart of CSRD reporting is the process through which the entity identifies the material impacts, risks and opportunities (‘IROs’) in relation to sustainability matters that should be included in the report (the ‘DMA process’). In the analysis, we paid special attention to what entities reported about possible changes to the DMA process and changes in IROs compared to the previous reporting period.

We continued to see a high degree of variability in how much and in what detail entities disclosed their DMA process. However, disclosures on changes made to the DMA process and to IROs were relatively comprehensive.

4. Material topics

The ESRSs specify the information that an undertaking shall disclose about its material impacts, risks and opportunities in relation to environmental, social and governance sustainability matters.

The material topics most frequently included in the CSRD reports analysed by us were the following (the figure indicates the occurrence of the topic in the reports as a percentage, and the previous year’s data is presented in brackets):

Own workforce (S1) 100% (100%)
Climate change (E1) 98% (96%)
Business conduct (G1) 97% (96%)

These three sustainability topics remained the most frequently addressed material sustainability topics. The gap to the next most discussed sustainability topic was clear: Resource use and circular economy (E5) was assessed as material in 71% of the reports (69%).

The least common material topics were:

Affected communities (S3) 17% (19%)
Water and marine resources (E3) 20% (22%)
Pollution (E2) 24% (31%)

What happened to the number of topical standards reported? In the majority of CSRD reports (72%), the number of standards applied remained unchanged compared to the previous year. The number of standards decreased in 17% of the reports, and increased in 8%, while in a few reports (3%) both additions and reductions of standards were observed.

The number of topical standards applied in the report was typically six, representing 21% of the reports we analyzed. Almost as common were four reported standards (19% of reports) and five reported standards (17% of reports).

Overall, the number of standards applied ranged from two standards (1% of reports) to ten standards (4% of reports).

The number of reported topical standards did not change much from 2025. At that time, the number of standards reported likewise ranged from two (1%) to ten (4%), with six standards being the most applied, representing more than 20% of the reports. The next most common numbers of reported standards were four and eight, each accounting for almost 20% of the reports.

In addition to changes at the level of topical ESRSs, changes were also observed at the level of sub-topics and sub-sub-topics.

5. Entity-specific disclosures

If entities identify material impacts, risks or opportunities not covered or not covered with sufficient granularity by the topical ESRS standards, they are required to provide additional ‘entity-specific’ disclosures.

References to entity-specific disclosures became more common in the reports: such disclosures were identified in more than 40% of the reports. Compared to the previous year, the change was clear, as such disclosures were identified in more than 30% of the reports.

Entity-specific disclosures related particularly to cybersecurity, data protection and data security. Entity-specific disclosures were also provided on AI.

It will be interesting to see how the provision of entity-specific disclosures will evolve in the future. In the Draft Simplified ESRS submitted by EFRAG to the EU Commission in December 2025, the relevance of entity-specific disclosures is emphasised, along with the link between such disclosures and fair presentation.

One way or the other, if entity-specific disclosures are given, it is important for the reader of the CSRD report to know what they are and where to find them in the report.

6. Independent assurance

The Finnish Auditing Act requires for independent assurance of sustainability reports, at least at a limited assurance level.

The assurance conclusion expressed, or the assurance opinion, was unqualified (‘clean’) in all assurance reports that we analysed. This was also the case in the previous year’s study.

One fifth of the assurance reports included either an Emphasis of Matter paragraph or an Other Matter paragraph.

In an Emphasis of Matter paragraph (1% of the assurance reports), the assurance provider drew attention to the information presented in the CSRD report, noting, inter alia, that estimates introduce uncertainty into the reported environmental and GHG emission information.

In an Other Matter paragraph, the assurance provider drew attention to the fact that the assurance opinion does not cover comparative information for periods prior to the first year of assurance, i.e. the year 2024 (17% of the assurance reports). In addition, regarding comparative information, it was disclosed as an Other Matter that the prior year CSRD report was assured by a different authorised sustainability auditor (2% of the assurance reports).

All assurance reports included a description of the inherent limitations associated with preparing a CSRD report.

Uncertainty relating to forward-looking information was mentioned as an inherent limitation in all assurance reports. In addition, three-quarters of the assurance reports referred to one or more other inherent limitations, such as management judgements and choices related to the DMA process, sustainability reporting-related estimates, assumptions, and measurement and assessment uncertainty, particularly in the measurement of greenhouse gas emissions.

Looking ahead – the path of change continues

Over the first two years of reporting CSRD reports, sustainability reporting in the EU has moved towards a more robust and increasingly harmonised framework. The development of reporting processes and capabilities continues, and best practices are gradually becoming established, although the overall framework remains partly in transition.

At the time of writing, the second phase of the EU’s so-called Omnibus package is being implemented in Finland. As a result of the legislative amendments, the scope of entities subject to sustainability reporting obligations is set to be significantly reduced from the current level, and reporting requirements will be reduced.

The ESRS standards are also undergoing changes, with the aim of simplifying and clarifying the current standards. It remains to be seen whether the European Commission will still succeed in publishing the revised standards during the first half of this year.

The effects on reporting practices will become evident later. Despite all the changes affecting sustainability reporting, it is clear that the need for high-quality sustainability reporting that is relevant to decision-making is here to stay.