What the Beer Giants Teach Us About CSRD Reporting Maturity

How CSRD Reporting Maturity Differs Even Under ESRS Compliance

CSRD reporting maturity is often assumed to guarantee comparability. If companies apply the same ESRS compliance framework and conduct a double materiality assessment based on identical principles.. If you apply the same sustainability reporting standards for companies in the same sector, conduct a double materiality assessment based on the same principles, then logically, the outputs should look similar.

The 2025 sustainability statements of three multinational brewers prove otherwise.

Carlsberg Group, Heineken N.V., and Anheuser-Busch InBev (AB InBev for short) all published ESRS-compliant disclosures with limited assurance. They operate in the same industry. They face similar packaging pressures, climate exposure, and supply chain risks. Yet their sustainability statements differ dramatically in structure, clarity, and strategic coherence.

This is not about who is “more sustainable.” It is about reporting maturity, and how different reporting strategies using the same standards lead to very different stories about sustainability performance

Three Companies, Three Different Philosophies

Start with the basics. Carlsberg's 2025 sustainability statement runs to 55 pages. Heineken's comes in at 121 pages. AB InBev, the largest brewer of the three, manages the full ESRS disclosure in 37 pages.
Length alone tells you almost nothing about quality: with a sharp and focused narrative and clear metrics, short ESRS statements can provide the right amount of decision useful information, while long ones often dump way too much unnecessary, immaterial information and fluff on the reader. Let’s if that’s the case with our brewers as well!  

Carlsberg

Carlsberg, the smallest of the three by revenue at €11.93 billion, uses the ESRS structure as a genuine strategic reporting framework. Their sustainability statement sits before the financial statements. A deliberate choice that reflects the Scandinavian interpretation of ESRS, which treats the sustainability disclosure as integral to the management report rather than appended to it.  

The narrative follows a clear and logical chain.It starts with a material topic, described through the impacts, risks, and opportunities that made it material. This is followed by the policies that govern actions related to the topic. The report then explains the specific actions taken to mitigate risks and negative impacts and to realise opportunities. Next come the targets and metrics defined for these actions.

Finally, the company presents evidence of progress in the form of well-defined, clear KPIs, including the related accounting policies. As a result, the reader can clearly trace how the company’s assessment of its most significant impacts and risks is directly connected to what it is doing about them.

Carlsberg's 2025 Sustainability Report

Heineken

Heineken, with €28.8 billion in revenue and the most extensive report of the three, opens its sustainability statement with five pages of what the sustainability community might charitably call legacy communication. This content is entirely legitimate, but its placement signals an organization that has not yet fully resolved the tension between sustainability as a marketing message and sustainability as financial-quality disclosure.  

Heineken also pushes a significant amount of information into appendices, a structural choice that technically satisfies disclosure requirements while obscuring the narrative connections that make disclosures useful.

Heineken's 2025 Annual Report

AB InBev

AB InBev's 37-page report presents another dynamic. Yes, it does cover required disclosures, but it often lacks when it comes to showing how individual disclosures relate to each other and thus there’s no clear picture emerging about ABInbev’s sustainability initiatives and progress. They might be the most sustainable of the three – but you wouldn’t be able to tell it based on their report.

The contrast demonstrates a core reality of ESRS reporting: compliance is binary, but maturity is not.

AB InBev's 2025 Sustainability Report

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The Comparability Illusion Under ESRS

The clearest illustration of this maturity gap is in how these three companies disclose their resource use and circular economy commitments. All three brewers identify similar impacts, risks, and opportunities:

• Purchasing of packaging materials: The large-scale procurement of packaging materials relies heavily on raw material extraction. The intensive use of both biological and mineral virgin resources has a significant impact on nature and the environment and may contribute to resource depletion and scarcity. ‍
• Post-consumer packaging waste: If not properly managed and disposed of, packaging waste may end up in natural ecosystems, including waterways and oceans. Additionally, incineration and landfilling of packaging materials can contribute to air and soil pollution.  

Packaging Targets and KPIs

The three beer gaints have targets aimed at increasing the recyclability or reuse of their packaging by 2030.  

• Carlsberg aims to ensure by 2030 that all packaging is recyclable, reusable, or renewable (100%) and that 90% of bottles and cans are collected and recycled post-consumption. Furthermore, the company targets a 50% reduction in virgin fossil-based plastics and 50% recycled content in bottles and cans.
• Heineken has established targets to achieve by 2030 to increase volumes sold in reusable formats to 43%, achieve 50% recycled content in bottles and cans, and ensure that 99% of all packaging is recyclable by design.
• AB InBev has set targets to ensure that 100% of its products are sold in packaging that is returnable or made primarily from recycled content. Originally targeted for 2025, this goal has now been extended to 2030.

To contextualize these commitments, it is essential to evaluate the current progress against these ambitious targets, based on disclosures in the 2025 annual reports.

• Heineken reports that 43% of volumes are sold in reusable formats and that 99% of packaging is recyclable by design.
• Carlsberg reports that 51% of the material used in its bottles and cans is recycled content. Of this, 26% consists of recyclable PET material.
• AB InBev states that 89.7% of products are in returnable formats or use a majority of recycled content, highlighting a 10.6 percentage point improvement since 2017.

These three data points cannot be compared. They measure different things: reusability, recyclability by design, and returnable format are related but distinct concepts with different environmental implications and entirely different measurement methodologies.

The denominators differ. The definitions differ. The boundary choices differ. A sustainable finance analyst trying to benchmark these companies against each other would need to essentially reconstruct the underlying data from scratch.

This is not a flaw in the companies. It is a structural limitation of current sustainability reporting standards. Even with full CSRD compliance and limited assurance, peer comparison remains complex without sector-specific harmonization.

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The AB InBev Calculation Challenge

The AB InBev report deserves a closer look, because it illustrates a distinct mode that is separate from the marketing-versus-disclosure tension visible in Heineken.

Its packaging section includes:

• Returnable packaging percentages
• Recycled content metrics for glass and aluminium
• Recycled PET disclosures

AB InBev’s circular packaging disclosure is a good example of how sustainability KPIs can be technically correct yet difficult to interpret. The company’s 2025 goal was that 100% of its primary packaging would either be in returnable formats or made from majority recycled content (more than 50%). In 2025, it reports achieving 89.7% against this goal. The confusion arises because this figure is not derived from the average recycled content percentages shown in the progress table. Instead, it combines two volume shares: returnable packaging and one-way packaging formats that individually exceed the 50% recycled content threshold.
Average recycled content by material (glass, cans, PET) is a separate metric and does not directly translate into the percentage of packaging that qualifies under the goal.

The disclosure is therefore defensible from a methodological perspective, but it lacks a transparent bridge explaining how the 89.7% is calculated. The report does not clearly show how much of the packaging volume in each format exceeds the 50% threshold, which makes it difficult for readers to verify the headline number.

This illustrates a broader reporting lesson: compliance with structured standards such as ESRS improves consistency, but decision-usefulness depends on clarity. Composite KPIs should be accompanied by simple reconciliation tables that allow readers to understand and validate the calculation without reverse-engineering the logic.

What Mature CSRD Reporting Maturity Looks Like

Across these examples, two maturity markers stand out:

1. Structure Over Length - Carlsberg’s 55 pages provide greater clarity than significantly longer disclosures because the PATM chain is intact and readable.

2. Transparency About Comparability Limits - Leading reporters explicitly acknowledge boundary changes, acquisitions, and metric recalculations. They do not imply artificial comparability.

The Bigger Lesson for CSRD Preparers

The 2025 brewing sector demonstrates a simple but uncomfortable truth.

Two companies can conduct rigorous double materiality assessments, produce limited-assurance ESRS disclosures, and still appear to operate on different planets from a reporting perspective.

The difference lies in whether ESRS reporting is treated as:

• A compliance checklist
• A communications vehicle
• Or a strategic sustainability governance architecture

The companies best positioned for regulatory scrutiny, investor confidence, and audit resilience are those that treat information architecture as seriously as the metrics themselves.

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The maturity gaps highlighted in this article were discussed in depth during a recent denxpert webinar led by senior sustainability expert Anna Csonka. If your organization is preparing for upcoming CSRD reporting cycles, the on-demand recording offers a practical lens on how to strengthen your own ESRS disclosure architecture.

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