Corporate sustainability reporting: AMF draws listed companies' attention to ESMA's 2025 recommendations

Each year, the European Securities and Markets Authority (ESMA) establishes common supervisory priorities at European level in the area of reporting, which constitute recommendations for listed companies in preparation for their annual financial reports. ESMA presents specific recommendations on the preparation of sustainability statements.

On October 14, 2025, ESMA published the new European Common Enforcement Priorities (or ECEP) related to corporate reporting. As every year, these recommendations cover the different aspects of the annual financial report (financial reporting, sustainability reporting, digital format). The AMF presents below the specific recommendations on the preparation of the sustainability statements for 2025, the second year of application of the Corporate Sustainability Reporting Directive (CSRD).

A particular context in 2025

In its communication, ESMA emphasizes the particular context of 2025, linked to ongoing developments in the regulatory framework and the lack of transposition of the CSRD by certain Member States. ESMA summaries the latest developments in the revision of the CSRD, its European Sustainability Reporting Standards (ESRS), and Taxonomy reporting:

CSRD: publication by the European Commission in February 2025 of the Omnibus package, aimed at reducing the administrative burden on companies. It includes the “Stop the Clock” directive, which has already entered into force and postpones the implementation of the CSRD for large unlisted companies and SMEs by two years, and the “Content” directive, which is still under negotiation and makes substantial changes to the CSRD and its scope.
ESRS: EFRAG's ongoing work to simplify ESRS standards. In the meantime, publication by the European Commission of a “quick fix” to the ESRS to extend the transitional provisions that listed companies can already apply when preparing their second sustainability report. ESMA reminds companies that the current ESRS framework, as simplified by this quick-fix, remains applicable for the 2025 reporting period.
Taxonomy reporting : pending a thorough review of the texts, quick-fix modification of taxonomy reporting obligations and certain sustainability criteria related to pollution. Provided that the text is published on time, companies should be able to voluntarily apply these simplifications as early as their next reporting cycle in 2026.

Furthermore, 2025 is also the first year in which European regulators will supervise the sustainability statements published by listed companies. Pursuant to the European Transparency Directive, the AMF is in France the competent authority responsible for controlling this information.

In 2025, in line with its communication accompanying the publication of its 2025 action and supervisory priorities, the AMF adopted a pragmatic and understanding approach to the supervision of issuers' sustainability information, while using ESMA's supervisory priorities as a reference. In addition, it published its main findings in an anonymized study in order to contribute to the ongoing review of ESRS standards (see “Read More” section).

In 2026, the AMF should maintain the same supervisory approach. It has chosen not to comply with ESMA's new guidelines on the supervision of sustainability information (Guidelines on Enforcement of Sustainability Information or GLESI) as not all EU countries have yet transposed the CSRD into national law, which means that not all regulators are able to fully apply these common guidelines.

Two European enforcement priorities for sustainability reporting

Due to this regulatory context, ESMA has exceptionally reconducted two of the priorities already defined in 2024 for 2025:

Priority 1 : materiality considerations in reporting under ESRS

ESMA emphasizes the fundamental nature of materiality analysis, which consists of identifying the principal sustainability impacts, risks, and opportunities for the company.
It recalls the transparency requirements relating to the assessment process: information on the input parameters used (sources, scope, assumptions), on materiality thresholds, on the consultation with affected stakeholders, etc. It invites companies to publish information that is relevant to their facts and circumstances.
ESMA also presents recommendations on the results of the materiality assessment, emphasizing the connection with the company's strategy and business model. It encourages companies to use the categories of topics and subtopics proposed in the ESRS where possible.
It reiterates that non-material information must be clearly identifiable and must not obscure material information.

Read more : ESMA has published a fact-finding exercise on companies' reporting practices relating to the materiality assessment (cf. “Read more” section).

Priority 2 : scope and structure of the sustainability statement

ESMA reminds issuers that the consolidation scope of the sustainability statement should, in principle, be the same as that of the financial statements. It specifies that the scope of the information disclosed is extended to cover information on the material impacts, risks, and opportunities that are connected with the company's value chain.
It recommends transparency on the limitations related to the value chain coverage and on changes in the scope of the targets from one year to the next.
ESMA notes the flexibility of ESRS in terms of the structure of the sustainability statement, but emphasizes the overall objective to facilitate access and understanding of the reported information. With this in mind, ESMA encourages companies to mention, for example, the exact reference of the Disclosure Requirements corresponding to the information disclosed (e.g., mention the reference “E2-5”).
Finally, it emphasizes the importance of connectivity between the financial information presented in the sustainability statement and the financial statements.