ESRS Implementation under the CSRD : A Comparative Directed Qualitative Content Analysis of Ten Corporate Cases

ABSTRACT

This paper investigates how large firms are responding to the Corporate Sustainability Reporting Directive by implementing the European Sustainability Reporting Standards in their first reporting cycle. Drawing on institutional and legitimacy theory, it applies a directed qualitative content analysis to sustainability reports of 10 companies across diverse sectors. The analysis focuses on ESRS cross‐cutting requirements (ESRS 1 and ESRS 2), including double materiality assessment, as well as selected topical standards: climate change (E1), resource use and circular economy (E5), workers in the value chain (S2), and governance and business conduct (G1). Findings indicate growing uniformity in the structure of ESRS reporting, but substantial variation in how rigorously firms apply the standards in practice. The study offers one of the first cross‐company assessments of ESRS implementation and clarifies how coercive regulation can standardise disclosure form without guaranteeing substantive organisational change.