Second round of CSRD reporters are taking different approach to first, says PwC

The next batch of companies that will have to report against the EU’s Corporate Sustainability Reporting Directive (CSRD) are taking a different approach to compliance than the first, says PwC.

The accountancy giant surveyed more than 200 firms covered by the law and found those preparing to publish inaugural reports in report in 2026 – known as the ‘Second Wave’ – are far less likely to be using financial accountants for the process or have the documents approved by their CEO than the ‘first wave’.

More than half (56%) the respondents due to issue sustainability statements for the 2024 financial year told PwC that financial accountants were the main source of experience they tapped to develop their CSRD implementation roadmap.

This was the case for just a quarter of those set to start reporting on the 2025 financial year. Another quarter (25%) said they would mainly rely on non-financial accountants, and another (24%) on internal sustainability advisors.

While 27% of ‘First Wave’ companies will get their reports signed off at the very top level, by the CEO of equivalent, this is only the case for 9% of Second Wave firms, more than 20% of whom will get it rubber stamped by a Chief Sustainability Officer. Just 10% of First Wave firms will use a CSO for approval.

Both groups are most likely to have CSRD reports approved by the Chief Financial Officer, according to the survey.

There are a number of possible reasons for the differences.

One is that the first companies covered by the new law were already required to report under the EU Non Financial Reporting Directive, so they’ve got experience of regulatory compliance for sustainability disclosures. As a result, they’re more likely to have processes and board-level governance in place already. They’re also Europe’s biggest companies, so they have more resources.

As compliance is  further down the line for Second Wave companies, it’s possible their approach may shift to align more closely with First Wave companies as they realise the realities of reporting under CSRD.

Perhaps the biggest difference in the way the two sets of companies are thinking about CSRD compliance is that, while half of First Wave firms see it as a strategic undertaking, just 9% of the Second Wave do – two-thirds (63%) say it’s a compliance activity.

PwC notes that the focus on compliance is “understandable” given that CSRD reporting “marks for a majority of entities in the Second Wave the dawning of a new age” as they issue their first ever regulated sustainability reports.