Disability Hub Europe (D-Hub) is proud to present its latest publication “Disability Disclosure Under the CSRD: Benchmarking the First Wave of Sustainability Reports” — a comprehensive analysis of how companies are already integrating disability inclusion into their sustainability disclosures under the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS).
Why This Matters
Disability inclusion is not a peripheral issue; it is central to the social dimension of sustainability. With over 100 million citizens in the EU and 1 billion people worldwide living with disabilities, embedding inclusion into corporate strategies and reporting is essential for a just transition.
The CSRD and ESRS frameworks provide unprecedented opportunities for companies to disclose social impacts, risks, and opportunities — including those related to disability. This report captures how early adopters are responding to these requirements.
About the Report
This benchmarking study reviewed 100 CSRD-aligned sustainability reports published in 2025 for FY2024. It builds on D-Hub’s previous guide, and offers a first snapshot of disability-related disclosures under the new EU framework.
Key Findings:
- Early traction for S1-12: 41% of companies disclosed the percentage of employees with disabilities using ESRS S1-12, with nearly half providing gender-disaggregated data.
- Disability mentions are mainstream: all companies analysed referenced disability or related concepts in their reports.
- Beyond workforce inclusion: disability-related content appeared across more than 40 ESRS sections, from governance to consumer engagement.
- Quality matters: companies reporting under S1-12 were significantly more likely to include specific policies, actions, and targets (PATs), moving beyond general statements.
- Need for structure: while progress is evident, many disclosures remain unstructured, highlighting the importance of standardisation for comparability and accountability.
- Safeguarding visibility: future regulatory revisions must maintain disability-related provisions in ESRS to avoid undermining progress.
With over 11,000 companies expected to publish CSRD-aligned reports in 2025, this first wave sets the tone for inclusive sustainability reporting.
The findings underscore the importance of safeguarding disability visibility in future regulatory revisions and maintaining ESRS provisions that drive meaningful action.