Analysis of Four of the First Regulated Reports under CSRD – Part 1: How Ørsted Visualizes Its Path to Decarbonization

The first sustainability reports prepared in line with ESRS standards are now emerging. Since the adoption of the CSRD directive in 2022, experts have been eagerly awaiting the first examples of such reports from companies in the so-called first wave. These are companies that were already required to disclose selected non-financial information in their annual reports under the 2014 Non-Financial Reporting Directive (NFRD), or that joined this obligation at a later stage.

The market mainly anticipated the first reports under the new legislation to see how large companies would demonstrate what ESG reporting should look like in practice. However, this article does not evaluate their success – instead, it highlights examples of good practice that can inspire further work with sustainability.

Our analysis, presented at this year’s 3rd Czech & Slovak Sustainability Summit, focused on four companies from different industries and European countries: the Danish energy company Orsted, the Swiss holding Coca-Cola, Slovakia’s Tatra Bank, and the Dutch ASM. In this article, we will take a closer look at Orsted.

Ørsted and Sustainability: Examples of Best Practices

The Danish energy company Ørsted is among the pioneers in sustainability. Last year, we included its 2023 report in our analysis of ESG reporting by 100 major European companies.

The 2024 report – the company’s first prepared under the new European legislation – is clear, visually attractive, and firmly anchored in the company’s core mission: decarbonization. Graphics clearly illustrate the value chain and key commitments to readers.

In its double materiality analysis, Ørsted engaged employees from various departments in internal workshops. They discussed predefined impacts, risks, and opportunities, added new ones, and jointly assessed them according to established criteria. The finance, sustainability, and investor relations teams also took part in the process, bringing in the perspective of external stakeholders. Interestingly, for topics related to human rights (where Ørsted had already classified categories ESRS S1–S3), the company assigned three times greater weight to severity than to likelihood of impacts – in line with European standards (specifically paragraph 45 of ESRS 1).

Ørsted’s visual materiality matrix can also be seen as an inspiration. It does not force diverse topics into a single ranking but instead shows them in the context of impacts and financial materiality.

The company places great emphasis on carbon footprint reporting. All results are externally verified, it discloses the sources of emission factors, and has also published its own Climate Advocacy Report, in which it evaluates sectoral decarbonization initiatives. The company motivates its executive management to meet climate targets through special KPIs linked to Scope 1 and 2. In the area of Scope 3, it actively engages with suppliers on SBTi commitments, which are also integrated into procurement processes.

At the same time, Ørsted supports nature-based solution projects, such as mangrove restoration in Gambia. In the field of circular economy, it openly describes the limits of recycling, especially with regard to steel, and is working on biodiversity targets in line with the Science Based Targets Network (SBTN) methodology.

Social Responsibility and Innovation

Ørsted does not include self-employed contractors in its workforce; however, the company does not sufficiently explain its reasoning in the report. It is therefore unclear whether such an approach complies with paragraph 4 of the ESRS S1 standard, which includes in the own workforce also those self-employed individuals without an employment contract who maintain a relationship with the company similar to that of employees. It is possible that the company classifies as external workers (and thus outside of its own workforce) only those contractors who do not have a permanent relationship with the company. However, this interpretation cannot be clearly derived from the report.

On the other hand, the company monitors indicators that go beyond the standards – for example, voluntary turnover or employee satisfaction. It also sets clear targets for gender equality, not only for management but for all employees (with the goal of a 60:40 ratio in favor of men).

Within its value chain, the company uses external risk ratings and communicates with trade unions to verify working conditions at its suppliers. An interesting innovation is a pilot project tracking the origin of purchased copper using blockchain. Ørsted plans to extend this system to steel in the near future. Transparent knowledge of the origin of materials is crucial for the company in terms of both environmental and social impacts and risks.

Ørsted as an inspiration for companies on the path to meeting new standards

Ørsted’s experience shows that the new ESG reporting requirements do not have to be just an administrative burden, but can become a tool for deeper work with sustainability. A clear structure, employee engagement, an emphasis on external data verification, and innovative approaches such as tracking material origins through blockchain all demonstrate that transparency and the courage to go beyond compliance can become a competitive advantage. The first regulated reports thus pave the way for other companies, showing how the new standards can be used not only to meet legislation but also to strengthen trust and long-term value.

Details on the approaches of other companies will be shared soon – in the meantime, you can already read the full analysis on the Ekonews platform, which, in addition to Ørsted, also covers the Swiss Coca-Cola holding, Slovakia’s Tatra Bank, and the Dutch company ASM.