As companies prepare their first Corporate Sustainability Reporting Directive (CSRD)-aligned sustainability statements and disclosures, or refine their Wave 1 reports, many are finding that meeting disclosure requirements is only part of the challenge.
CSRD introduces new expectations for sustainability disclosures, but it also raises a practical question: how do you organise, draft and present this information so it is clear, navigable and genuinely useful for the people reading it?
These questions were explored in a recent Flag webinar, with guest speaker Monica Keaney, ESG Reporting and Communications Manager at Carlsberg Group, drawing on practical experience from Carlsberg Group’s first two CSRD‑compliant reports.
In practice, strong CSRD sustainability statements balance regulatory compliance with clarity for investors and other decision‑makers.
Watch the webinar recording
Why structure and presentation matter in CSRD sustainability statements
CSRD sustainability statements are intended to support better decision-making by investors, regulators, leadership teams and, increasingly, AI tools used to interrogate reports. But as early filings are showing, compliance alone doesn’t guarantee that a report is understandable, navigable or useful.
Many CSRD reports include robust content but are difficult to use in practice because information is hard to find, links between disclosures are unclear or the narrative feels fragmented. Structure, hierarchy and presentation help bridge that gap, making it easier for readers to understand what matters, why it matters and how the organisation is responding.
Defining the role of your CSRD sustainability statement
Decisions about structure can’t be made without considering the purpose of your report. Before drafting begins, organisations need to be clear about what role their CSRD sustainability statement is expected to play beyond compliance.
For some, it will become the primary sustainability communication for a wide range of stakeholders. For others, it will act as a technical, assured backbone that sits alongside more narrative‑led channels such as websites, summaries or voluntary story-led reports.
This choice affects tone, depth, design and how much narrative context needs to be built into the report. There isn’t a single “right” approach, but being clear about purpose and intended audience early on helps avoid fragmented storytelling and rework later in the process.
Effective CSRD reports are decision‑useful, not just compliant
When people talk about CSRD reporting, they often focus on volume and complexity. But where sustainability statements are intended to serve investors and other key stakeholders, not just regulators, compliance alone isn’t enough.
The strongest reports emerging from early filers support decision-making. They explain how the business creates value and where it has impact. They clearly set out the business model, value chain, and material impacts, risks and opportunities (IROs). And crucially, they are easy to navigate and read.
A sustainability statement can be detailed without being hard to use – but only when structure, hierarchy and signposting are treated as core considerations, not an afterthought.
Why a clear content plan matters for CSRD reporting
Developing a clear, detailed content plan before drafting begins gives teams a bird’s‑eye view of how the report will flow and how disclosures relate to one another. This helps identify where key messages should sit, where high‑effort content or infographics are worth prioritising and how to avoid repetition across European Sustainability Reporting Standards (ESRS) topics. From a delivery perspective, it also makes drafting, assurance, tagging and design more efficient, reducing last‑minute changes and rework.
Use ESRS for compliance, but organise content in business‑relevant ways
Most early CSRD reporters have used the ESRS as their primary structural framework. However, ESRS topics don’t necessarily need to dictate narrative flow.
Within each topic, disclosures are often easier to understand when grouped into business‑relevant themes, rather than presented as a series of disconnected requirements. Using the outcomes of the double materiality assessment (DMA) to shape these themes creates a clearer line of sight from IROs through to strategy, actions, targets and performance.
In Carlsberg Group’s 2025 Sustainability Statement, its targets are used to group content thematically, helping readers understand IROs in context of business priorities. This treats the DMA as the backbone of the narrative, not just a compliance mapping exercise.
Writing CSRD disclosures for investors, stakeholders and AI
ESRS disclosures are written first and foremost for regulators. CSRD sustainability statements are designed to be machine read through structured data and XBRL tagging, enabling consistency and comparability.
At the same time, these reports are widely used beyond compliance. Investors, analysts and other stakeholders rely on them to understand performance, risks and direction, increasingly using AI tools to search and extract key insights from across complex reports.
Simple practices such as cross-referencing section headings rather than page numbers, writing acronyms in full, clearly stating definitions and explicitly labelling key takeaways, can improve usability for human readers while supporting accurate interpretation by AI tools.
Why collaborative, audit-ready tools matter for CSRD reporting
Preparing a CSRD sustainability statement brings together large volumes of data, detailed narrative disclosures and complex cross‑referencing, often across multiple teams and geographies. All of these contributors need to work from the same information, at the same time, with a clear audit trail.
Managing this process through disconnected tools such as Word documents, spreadsheets and email chains becomes increasingly difficult once assurance, tagging and design are introduced. These approaches may work for smaller, voluntary reports, but they struggle to meet the rigour, traceability and repeatability that CSRD requires.
For Carlsberg Group, using a collaborative reporting platform such as Workiva helped bring data, narrative and design into a single environment. Teams were able to work simultaneously with clear ownership, permissions and visibility over changes, reducing version‑control issues and increasing confidence in the disclosures.
Because CSRD reporting is ongoing rather than a one‑off exercise, tools that support roll‑forward of content, data links, tagging and layouts provide a stronger starting point for year two and beyond. This helps shift time and effort away from rebuilding foundations and towards improving disclosures and usability.
How design can lead to more effective CSRD disclosures
Design is not required for CSRD compliance, but it plays a critical role in making sustainability statements decision-useful for human readers.
Good design helps readers understand where they are in a report, find disclosures quickly and make sense of complex information. Carlsberg Group’s 2025 Sustainability Statement shows how intuitive navigation, consistent heading hierarchies, visible ESRS references and clear topic entry points can significantly improve readability. While these design features might sound obvious, Flag’s research found that fewer than half of Wave 1 reports apply these principles consistently.
Design is particularly important when communicating the more complex requirements of CSRD. Value chains often span multiple stages and geographies. IROs cut across topics and business functions. Emissions footprints involve several scopes and categories that are hard to interpret in isolation. In situations like these, text alone can quickly become abstract and difficult to follow. Thoughtful information design, including clear infographics and well‑structured tables, helps readers understand the context first, before moving into detailed disclosures.
For example, Carlsberg Group’s value chain infographic in its 2025 Sustainability Statement allows readers to understand the business model and footprint at a glance, and creates a consistent visual language that is reused throughout the report. That same visual approach is referenced in Carlsberg Group’s GHG emissions footprint, helping readers understand where emissions are generated across value chain stages and providing clear context for the strategy, targets and actions that follow.
Bringing structure, narrative and design together
Effective CSRD disclosures start with being clear on purpose and how the CSRD sustainability statement fits within your wider communications landscape. Where a report is intended to be used beyond regulatory compliance, then the way disclosures are structured and presented is just as important as the content itself. In practice, that means agreeing structure early, using ESRS to meet requirements while organising content around how the business operates, letting the DMA shape the narrative and using design to explain complex concepts and aid usability.
Need a hand?
Flag works with organisations at all stages of CSRD reporting, from first‑time filers to companies refining and enhancing their sustainability statements year on year. If you’d like to discuss how these principles apply to your organisation, get in touch at info@flag.co.uk.